Privacy Policy

The Firm is 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 our website.

It is important that you read this Privacy Policy, together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you; so that you are fully aware of how and why we are using your data. This Privacy Policy supplements such other notices and is not intended to override them.

Controller

This Privacy Policy explains how we may use personal information. For the purposes of the General Data Protection Regulation (GDPR) and other applicable data protection legislation (the Data Protection Laws), the Firm is a joint data controller (with  Valu Trac & AJ Bell Securities) and is responsible for your personal data.

 

What personal information do we collect?

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 as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes home address, email address and telephone numbers.
• Financial Data includes bank account.
• Transaction Data includes details about transactions and trades that you place with us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes your username and password (when using our online client portal), preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Communications Data includes your preferences in receiving information from us.

If you contact us by post, telephone, email or through our website, we may keep a record of that correspondence.

Telephone conversations with you may be recorded, where we are required to do so by law or by 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.

For the purposes explained in this Privacy Policy, we do not request from you any Special Categories of Personal Data (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health – neither genetic nor biometric data). Nor do we request, nor collect, any information about criminal convictions and offences. However, whilst we do not request such data, you may wish to provide us with certain Special Categories of Personal Data if you think this is necessary for your personal circumstances. If you do so, we will process it in accordance with the terms of this Privacy Policy.

 

How will we use the information we collect about you?

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 to which you seek to become a party;

(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:

• to enable us to provide the investment management services you require;
• to process your application to invest in our funds;
• to provide clients and investors with information relevant to their investment and our services;
• to ensure that our website is presented in the most effective manner for you and your device (eg cookies); and
• for all other purposes consistent with the proper performance of our investment management operations and services.

We may contact you by post, telephone or email. 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.

Security

All personal information provided to us is stored on secure servers. While we take all reasonable steps to protect your personal data, its security cannot be guaranteed. Once personal information has been received, we will use strict procedures and security software to prevent unauthorised access. All reasonable steps will be taken to ensure that your data is treated securely and in accordance with this Privacy Policy.

Transfers Abroad

Your personal information may be transferred to, and stored in, a destination outside the European Economic Area (“EEA”). It may also be processed by staff based outside of the EEA who work for us, or one of our third-party business partners. If your personal information is transferred, we will take all steps necessary to ensure it is held securely and in accordance with this Privacy Policy - in particular by ensuring the appropriate technical and organisational safeguards are in place.

Disclosure of Information

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 Firm.

 

Your rights in relation to your personal information

Data Protection Laws give you rights in relation to your personal information.

You may:

• check whether we hold information about you;
• ask to see a copy of the information we hold about you; and under certain circumstances:
  • ask us to rectify any inaccurate and/or complete any incomplete personal information we hold about you;
  • ask us to stop processing your personal information;
  • ask us to erase your personal information;
  • ask us to restrict the processing of your personal information;
  • ask us to provide your personal information to you in a structured, commonly used and machine-readable format and have it transferred to another provider of the same or similar services;
  • withdraw your consent to processing if so provided. 

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 open-ended/investment 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.

 

Retention of your personal information

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.

Cookies

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.

Some cookies may contain personal information relating to you and therefore such cookies will be processed in accordance with this Privacy Policy. When you start to use our website you will be asked whether you agree to the use of cookies. You can set your browser not to accept cookies and you can remove existing cookies from your browser. However, in a few cases some of our website features may not function as a result. Please see our Cookies Policy for more information about what cookies are, the cookies used on our website and how to disable them if required.

Other websites

Our website may contain links to other third-party websites. Clicking on those links may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of the websites you visit. This Privacy Policy only applies to our website.

Changes to our Privacy Policy

This version of the Privacy Policy was last updated on 1^st May 2020 We keep our Privacy Policy under regular review and any updates will be made on this webpage.

How to contact us

If you wish to exercise any of the rights set out above or if you have any questions or comments on this Privacy Policy, please contact us by either sending an email to: info@castlebayinvestments.com  or by writing to us at: Castlebay Investment Partners LLP Crosstrees House, 14 Sandyford Place, Glasgow G3 7NB, FAO David MacNeil, Compliance Officer.

Our registration number with the UK Information Commissioner’s Office is A1052102.

 

Cookies Policy

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with the best possible experience when you browse our website and also allows us to identify ways in which we can improve our website.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive: generally the name of the domain from which the cookie has come, a unique ‘ID’ and information about the cookie’s ‘lifetime’.

The cookies we use are "analytical" cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. The anonymous information gathered is used and analysed only at an aggregate level – none of this information is reviewed at an individual level and we do not use cookies to track people’s internet use after leaving our website. You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Name of cookie	Purpose	More information
NID	These cookies are used by Google to store user preferences and information when viewing pages with   Google maps on them.	Click here for an overview of privacy at Google.
OTZ	Google APIS cookie used by   Google Analytics. These cookies are used to collect information about how   visitors use our site. We use the information to compile reports and to help   us improve the site. The cookies collect information in an anonymous form,   including the number of visitors to the site, where visitors have come to the   site from and the pages they visited.	Click here for an overview of privacy at Google.
PHPSESSID	This cookie is used by our   server code to link a user to a session so that information about their visit   can be stored on the server as they move from one page to the next.	This cookie is essential to allow the website to operate without interruption or  delay.  This cookie is deleted once you close your browser.
cookieNoshow	This cookie hides the cookie   policy information panel on return visits to the site.	This cookie lasts for 1 year.

 

When entering this website, you will have been informed that by using the site you accept the terms of this cookie policy. You will not be asked again about cookies on subsequent visits to our website. 

Most web browsers allow some control of most cookies through the browser settings. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access parts of our site. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit http://www.allaboutcookies.org/

 

This website uses Google Analytics cookies. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.

We regularly review our use of cookies and, as such, this cookies policy may be regularly renewed to include up to date information about the cookies we use.

 

Contact us

If you have any queries concerning your data or this policy then please contact info@castlebayinvestments.com or write to us at:

David MacNeil

Partner

Castlebay Investment Partners LLP

Crosstrees House

14 Sandyford Place

Glasgow

G3 7NB