Privacy Policy

1. ABOUT THIS PRIVACY POLICY

Your privacy is important to us and this Privacy Policy is an overview to explain how we process (collect, use and hold) personal data (any information that identifies, or could reasonably be used to identify you). Please read through the policy carefully and if you have any queries, email privacy@quantifire.co.uk or look at Section 2 below to find alternative ways to contact us.

We anticipate that this privacy policy will apply to two categories of individuals or data subject (referred to also as “you” and “yours”) :

• Client Representatives: employees or other individuals representing our corporate clients;
• Investment Specialists: professional investors, analysts, advisors and equivalent professionals

(2). Making changes to this Privacy Policy:

We regularly review and update our Privacy Policy and data protection information and advise you to read it when you use our service or communicate with us (for example, respond to a request for feedback).  However, if we make a significant change (for example use your personal data in a way which you wouldn’t expect) then we will actively let you know, for example, by emailing you.

This Privacy Policy was last updated on 5th November 2021.  

2. ABOUT US AND HOW TO MAKE CONTACT

Controller

QuantiFire Ltd is the controller and is responsible for your personal data, (referred to as “QuantiFire” or “we” or “us” in the privacy policy). Our registered office is at Profile West Suite 2, Floor 1, 950 Great West Road, Brentford, England, TW8 9ES.  Our company is registered in England and Wales, company number 08204416. Our Email address is: privacy@quantifire.co.uk

Contact

The person responsible for our data protection in the UK is Mr Tim Dew whom you can contact:

• By filling in this online form: https://quantifirelimited.gdprlocal.com/uk
• By Post/mail: Mr Tim Dew, QuantiFire Ltd, Profile West Suite 2, Floor 1, 950 Great West Road, Brentford, England, TW8 9ES.
• By Email: privacy@quantifire.co.uk

Our representative in the EU is Mr Adam Brogden whom you can contact:

• By filling in this online form: https://quantifirelimited.gdprlocal.com/eu
• By Post/mail: Mr Adam Brogden, INSTANT EU GDPR REPRESENTATIVE LIMITED, Office 2 12A Lower Main Street, Lucan Co. Dublin K78 X5P8 Ireland.
• By Email: contact@gdprlocal.com
• By Telephone: + 353 15 549 700

We value your opinions and feedback so if you have any questions, comments or concerns regarding our Privacy Policy or data protection, please contact us using the details above.  Please keep us informed if your personal data changes during your relationship with us. 

3. HOW WE COLLECT PERSONAL AND OTHER RELEVANT DATA

(1). What is the personal data that we use and where do we get it from?

Personal data is any information that identifies, or could reasonably be used to identify, an individual. We do not collect special categories of personal data, (such as information about race, ethnic origin, politics, religion, trade union membership, health, genetics, biometrics, sex life or sexual orientation).  Nor do we collect any information about criminal convictions and offences.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity data: your name, last name, title. 
• Contact data: your employer’s identity, your work address, your work telephone number, your work email address.
• Profile data: including job function and expertise, investment interests (i.e. asset class, sector focus etc), employer investment profile (i.e. AUM, public share ownership information, etc) and details of interactions with you such as responses you have given to market research surveys.
• Website and Technical data: data that you submit to us via our website. 
• Marketing and Communication data: includes your preferences in receiving marketing messages from us relating to our clients and your communication preferences. 

(2). How is your personal data collected?

We use different methods to collect data from and about you including through:

1. Direct interactions. You may give us your personal data when you provide information to us directly, for example:

• When contacting us by email, post, phone, via our website or otherwise, for example, to make an enquiry, make a complaint or to provide feedback.
• By entering information into a feedback form or other online form or via an interactive website feature.
• By engaging with us on social media or registering or attend an industry event.
• When using our services or provide products and/or services to us.
• As you interact with our website, we will automatically collect Website and Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy: www.quantifire.co.uk/cookie-policy/ for further details.

1. Indirectly: when we collect information from other sources of information, for example from:

• Contact with our corporate clients and market intelligence databases.
• Client databases.
• Colleagues or individuals within an organisation (who may refer us to a specific individual).
• Social media sites such as LinkedIn.
• Trade organisations.
• Trade events.
• Government filings.
• Other public sources.

(3). What happens if you don’t want to give us your personal or other relevant data?

If you do not supply us with personal data, then you may not be able to benefit from our services as we may be unable to act on your behalf.  For example, if you provide incomplete feedback which are intended to be relayed to a third party, we may be unable to relay this information.

4. HOW WE USE PERSONAL AND OTHER RELEVANT DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you (or your employer, as our client).
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

(1). Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

(2). Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing. Where we have uploaded your personal data to our Investor Specialist database, we will rely on Legitimate Interests to send you direct marketing relating to our clients.  If you no longer wish to receive these messages, please email support@quantifire.co.uk. 

(3). Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see www.quantifire.co.uk/cookie-policy/.

5. DATA RETENTION: HOW LONG DO WE KEEP PERSONAL DATA FOR?

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

6. WHO DO WE SHARE PERSONAL AND OTHER RELEVANT DATA WITH?

When personal data and other relevant data is provided to QuantiFire Ltd that information is provided to our whole organisation. We share may share this data with the following third parties in the following circumstances:

• Our clients, during the course of providing our services such as processing feedback or other research.
• Our third-party agents and suppliers who process personal data in order to provide services to QuantiFire, for example, data storage providers.  
• To meet our legal and regulatory obligations such as to HMRC for taxation purposes.
• Public authorities who make a lawful request, including to meet national security or law enforcement requirements.
• When selling our business or carrying out associated business activities.

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 service providers 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.

7. TRANSFERRING PERSONAL DATA OUTSIDE OF THE UK

• Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
  • Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

  Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

8. SECURITY OF YOUR PERSONAL INFORMATION

(1). Our approach to security

We have implemented appropriate security measures, to protect your personal data under our control including from unauthorised access, improper use, alteration, unlawful or accidental destruction, and accidental loss.  In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Should you require further information regarding the security measure we implement, please contact us. 

(2). Your role

Please ensure that:

• Any personal data that you provide is accurate and up-to-date.
• Take reasonable care and safety when using your devices and the internet.
• Contact us immediately if you think or know your personal data has been used, compromised, or accessed without your express permission or if you have any other such concerns.

9. EXTERNAL WEBSITE LINKS AND SOCIAL MEDIA

Our websites may contain links to and from websites or platforms which are operated by third parties. We are not responsible for those websites and do not recommend or endorse them. We advise you to read the privacy policy and terms and conditions of any of those websites which you visit and raise any queries directly with the website owner/operator.

10. YOUR PERSONAL DATA RIGHTS

In addition to the right to receive information contained in this Privacy Policy, the law provides certain rights in relation to personal data. These rights can be exercised by emailing us at privacy@quantifire.co.uk or using the information in section 2 of the policy (“About Us and How to Make Contact) above.

You have the right to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

11. NON-PERSONAL INFORMATION

We also collect other relevant data and information which does not identify you personally (non-personal information). We may also aggregate information which you have submitted to us, or which we have obtained from other sources and which is not considered personal data in law as this date will not directly or indirectly reveal your identity.

12. COMPLAINTS AND DISPUTE RESOLUTION

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance using the contact details outlined below:

Contact details

Please contact Mr Tim Dew:

• By Post/mail: Attn: Mr Tim Dew, Quantifire Ltd, Quest House, Suite 2, Ground Floor, 125-135 Staines Rd, Hounslow, United Kingdom, TW3 3JB
• By Email:privacy@quantifire.co.uk