1. ABOUT US
1.2 Our data protection officer is located in 10 Throgmorton Avenue, London EC2N 2DL and can be contacted at firstname.lastname@example.org.
2. DATA PROTECTION LAWS
2.1 We have to comply with the Data Protection Act no 2472/1999, Law no 3471/2006 and from 25 May 2018 the General Data Protection Regulation (EU) 2016/679 when keeping personal data about you when we obtain, use, disclose or otherwise process such data.
3.1 We are committed to protecting your personal information and respecting your privacy.
3.2 This policy explains about the personal information that we collect from you, use and otherwise process in connection with your relationship with LightTower Partners as a customer or potential customer. In particular, we explain the kinds of personal information that we collect from you, how we collect it, what we use it for and who we may share your personal information with. By “personal information” we mean information about you where you are, or could be, identified.
4. CATEGORIES OF INFORMATION WE COLLECT
4.1 We collect personal information from you such as your name and contact details (such as office address and office email address), FCA number, your transactions with us, information about how you use our services and about how you use access to our websites. This may include information that you provide to us directly or through companies or agents we work with, as well as information which we collect when you use our services or through interviews or face-to-face meetings, applications, agreements, or through inquiries by mail, e-mail or telephone.
5. HOW WE COLLECT YOUR INFORMATION
5.1 We collect personal information about you whenever you use our services (whether services provided directly by us or by other companies, your investment advisors or agents acting on our behalf), through transaction with us or when you use our websites.
6. WHY WE COLLECT YOUR INFORMATION
6.1 We use your personal information to conduct our business and to provide you with the best possible services.
6.2 We also use your personal information to:
6.2.1 provide the services, and effect the transactions, you have asked us to provide;
6.2.2 communicate with you about the services you have asked us to provide;
6.2.3 provide you with marketing and offers from us (where we have your permission to do so);
6.2.4 improve our services; and
6.2.5 comply with our security obligations.
7. WHO ELSE MAY HAVE ACCESS TO YOUR INFORMATION
7.1 To best serve you, we may share your personal information with service providers that provide support services to us or that help us market our products and services. Service providers are third parties who perform services on our behalf. They are contractually restricted from using your information in any manner other than in helping us to provide you with the products and services available from LightTower Partners.
7.2 We may share your personal information with the managers who’s products we distribute and work with to better perform our services.7.3 We may also disclose your personal information to a third party when you ask us to do so or when we believe it is required by law.
8. COUNTRIES HAVING ACCESS TO YOUR INFORMATION
8.1 For data storage reasons we are unable to store all of your personal information in the United Kingdom. Our servers, storing and keeping your information secure, are located in countries which have an adequate level of protection or with which we have signed agreements incorporating the Model Contract Clauses.
9. YOUR CONSENT
10. COLLECTING YOUR INFORMATION LEGALLY
10.1 We are able to legally collect and use your personal information either because:
10.1.1 you have provided us with your consent to do so as explained above; and/or
10.1.2 collecting and using your personal information is necessary for us to carry out our legitimate business interests in order to carry out any requests made by you via our Website.
11. RETENTION OF YOUR INFORMATION
11.1 We will only retain your personal information for as long as it is necessary to carry out our services, keep you up to date with LightTower Partner’s promotions, the status of the relevant funds in which you are interested and where you have asked us to send this information or to provide you with the best customer experience possible. Processing is therefore necessary for the purposes of our legitimate interests (for example, to deal with any claims or queries which you have relating our services), or where we are required to do so by law.
12. YOUR RIGHTS
12.1 You have the right to:
12.1.2 obtain confirmation from us that your personal information is being collected and used by us and to access the personal information held about you by us;
12.1.3 have your personal information corrected if it is inaccurate or incomplete at any time;
12.1.4 erasure, or the right to be forgotten, which means you can request deletion or removal of any personal information we hold about you at any time;
12.1.5 block or suppress us collecting and using your personal information, which means we can continue to store your personal information but we cannot further collect or use it in any way;
12.1.6 obtain and reuse any personal information we hold about you for your own purposes across different services, which allows you to move, copy or transfer your personal information easily from LGBR to another place notified by you to us in a safe and secure way without hindrance to the usability of your personal information; and
12.1.7 object to us collecting or using your personal information where this is based on:(a) a legitimate interest or the performance of a task in the public interest; or(b) direct marketing.
12.2 To make any requests as listed above, please contact us at email@example.com.
12.3 We will confirm any requests relating to your rights above within one month of receipt of your request, or within two months of receipt of your request where this request is more complex.
13. WITHDRAWAL OF YOUR CONSENT
13.1 You can tell us to stop collecting and using your personal information at any time by emailing us at firstname.lastname@example.org.
13.2 If you tell us to stop collecting and using your personal information, the consequences of doing so are that:
13.2.1 we will be unable to update you on our promotions and product news;
13.2.2 we will be unable to provide you with the best user experience possible to our Website;
13.2.3 we will generally be unable to provide you with the best customer experience we would like to provide you with; and
13.2.4 we will be unable to keep you updated on the performance and/or development of any funds in which any of your clients have invested.
14. COOKIES AND OTHER SIMILAR TECHNOLOGIES
14.2 A cookie is a small data file that is placed on the hard drive of your computer when you visit a website. A “session cookie” expires immediately when you end your session (i.e., close your browser). A “persistent cookie” stores information on the hard drive so when you end your session and return to the same website at a later date, the cookie information is still available.
14.3 When you visit our website, we may use both a session and a persistent cookie. This LightTower Partners-placed cookie may contain information (such as a unique user ID) that is used to track your usage of our website and in some cases, your email address.
14.4 You can disable cookies at any time by using your browser options. You can find out more about cookies by following this link: https://ico.org.uk/for-the-public/online/cookies/.
15. CHILDREN’S PRIVACY
15.1 We do not knowingly collect any information from anyone under 16 years of age. Our website, products and services are all directed to people who are at least 16 years old or older.
15.2 If you are under 16, do not use or provide any information on this website or on or through any of its features/register on the website or provide any information about yourself to us, including your name, address, telephone number or email address.
15.3 If we learn we have collected or received personal information from a child under 16, we will delete that information.
15.4 If you believe we might have any information from or about a child under 16, please contact us at email@example.com.
16. LINKS TO OTHER WEBSITES AND SERVICES
17. YOUR INFORMATION, YOUR CHOICE
17.1 To update us with your information-sharing preferences, you may contact us using one of the following methods:• call 020 7071 3920;• email firstname.lastname@example.org; or • send your request to LightTower Partners, 10 Throgmorton Avenue, London EC2N 2DL.
18.1 We shall implement appropriate technical and organisational measures to ensure a level of security appropriate to potential risks, including:
18.1.1 the pseudonymisation and encryption of your personal information where appropriate;
18.1.2 ensuring ongoing confidentiality, integrity, availability and resilience of processing systems and services;
18.1.3 ensuring we can restore access to personal information in a timely manner if a physical or technical incident occurs; and
18.1.4 regular testing, assessment and evaluation of the effectiveness of our technical and organisational measures to ensure your personal information is secure.
18.2 We maintain physical, electronic and procedural safeguards to protect the confidentiality and security of personal information transmitted to us using our Website.
19. BUSINESS TRANSITIONS
20. POLICY CHANGES
20.1 This policy replaces all previous disclosures we may have provided you about our information practices. We reserve the right to change this policy, and to apply any changes to information previously collected, as permitted by law. If there are material changes to this policy or our information practices change in the future, we will notify you by posting the policy changes on our website.
21. MAKING A COMPLAINT
21.1 We pride ourselves on excellent customer service, but if you would like to make a complaint about the way we have collected or used your personal information, please contact us at email@example.com.
21.2 If you are unhappy about the way we have handled your complaint and/or you would like to take the matter further or make a complaint directly to our regulator without contacting us first, you can do so by contacting the Information Commissioner’s Office (“ICO”) by following this link: https://ico.org.uk/concerns/ or telephoning the ICO helpline, which is 0303 123 1113.