Section 1 – Introduction
At Clifford Morton we manage your personal data in compliance with all applicable data protection laws. We commit to ensuring that there is transparency in how we process personal data. This policy covers the following topics:
- An explanation of the data we are processing
- Why we are processing that data and what we do with it
- Whether we will share it with anyone else
- Whether we will transfer it outside of the United Kingdom
- How we keep your data safe
- Your rights in relation to your personal data
Section 2 – About us
Our company name is BDB Promotions Ltd and our trading name is Clifford Morton. We are headquartered at No.1 Canada Square, Level 37, Canary Wharf, London E14 5AB. In this policy we have referred to Clifford Morton as: we, us or our.
For any queries concerning your data please contact the Data Protection Appointed Director by email at [email protected]
We are a marketing agency working within the private investments sector in the UK.
Section 3 – Your personal data
In order for the business to operate we will process your data if we believe you may be interested in the investment products or services we work with. In this section we provide detailed information about how we will manage your personal data.
What data do we hold about you and how have we obtained this?
We will obtain information about you when you enquire about the products or services we market. The information that we obtain might include: name, email address, phone number, date of birth address, employment history and credit history.
If you have visit www.cliffordmorton.co.uk we may automatically collect personal information including: details of your browser and operating system, the website from which sent you to our website, the pages that you visit on our website, the date of your visit, and the Internet protocol (IP) address assigned by your internet service. Some, but not all, of this information is collected using cookies. For more detailed information about Cookies Section 5 of this policy. We may also collect any personal information which you allow to be shared that is part of your public profile on a third party social network.
Telephone calls – with the Clifford Morton team and with outsourced partners we work with – may be recorded for training purposes or be used to verify any comments that were made during any conversation.
Sometimes you will have sent your information directly to us, but you may have provided your information to third parties including: other marketing providers who, in turn, provided the information to us.
How do we use your personal data and what is the applicable lawful basis?
Where you are an individual, sole trader or unlimited partnership and have provided consent, we:
- may provide you with marketing information about our products or the products and services of our selected partners
- we will keep you informed of events that we think will be of interest to you
- we will use your interaction with our website to identify products that are most relevant to you and deliver related messages to you
Where we are required to do so to perform our contract with you, we may process your information for maintaining records, providing settlement fees or other similar activities.
We may process your information to comply with legal obligations including assisting HMRC, the Police or other similar bodies.
Where applicable we may process your information to allow us to pursue our legitimate interests including for:
- analysing our performance to further improve our customer services
- market research, training and to administer our websites
- the prevention of fraud or other criminal acts
- undertaking credit checks for finance
- Keeping you informed of events we think will be of interest to you
- Use your interaction with our website, including chat functionality, to identify products which will be most relevant to you and deliver targeted and relevant messages to you
- Enforcing our legal rights or to defend legal proceedings and for general administration purposes
- Providing you with marketing information about our products or the products and services of our selected partners
Will we share your personal data with any third parties?
We may disclose your information to our third-party service providers for the purposes of providing services to you. For example we may be required to pass on your details to investment partners that we work with. In the provision of services we may pass your data to companies such as marketing agencies or administrative service providers.
When we use third party service providers, we only disclose to them any personal information that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.
If we sell all or part of our business to a third party, we may transfer your information to that party to ensure that it can continue to provide information that you have requested or for any of the other purposes that we have noted above.
We may transfer your data to government or other official bodies for the purposes of complying with legal obligations, for enforcing our rights, or for the prevention or detection of a crime.
How long do we keep your data?
If you have expressed an interest in buying products from us or from selected Clifford Morton Investment partners, we will retain your contact details and related information concerning your enquiry for two years from the date that we last had contact with you.
If you have purchased products from us or from our selected investment partners, we will keep the data relating to that purchase (e.g. order forms and invoices and related correspondence) for 7 years from the termination of the contract or the most recent financial transaction.
Records of any discussions through our web chat facility will be kept for one year.
If you request that Clifford Morton does not send you marketing information we will always retain sufficient information to ensure that we remember to comply with your request.
The periods stated in this section may be extended if we are required by law to keep your data for a longer period.
Section 4 – Transferring your data outside of the United Kingdom (‘UK’)
The information that you send to us may be transferred to countries outside of the countries outside the UK. By way of example, this may happen should Clifford Morton be incorporated in a country outside of the UK. Alternatively, if any of our servers or those of our third-party service providers are located in a country outside of the UK. These countries may not necessarily have similar data protection laws to the UK.
If we transfer your information outside of the UK, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected. These measures include imposing contractual obligations on the recipient of your personal information or ensuring that the recipients are subscribed to ‘international frameworks’ that aim to ensure adequate protection. Please contact us if you would like more information about the protections that we put in place.
If you use our services whilst you are outside the UK, your information may be transferred outside the UK to provide you with those services.
Section 5 – Cookies
You can find out more about the Cookies we use in our Cookies Policy available on our website.
You can set your browser not to accept cookies, however some of our website features may not function as a result.
Section 6 – Data security
We have adopted appropriate technical and organisational measures to protect the personal data we collect and use. In this regard we consider the nature of the data stored and the risks to which the data is exposed to human action or the physical or natural environment. However, as effective as our security measures are, no security system is impenetrable. We cannot guarantee the security of our database.
The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use procedures and security features to try to prevent unauthorised access
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Section 7 – Links to other websites
Section 8 – Your rights
Your right to access data
We always aim to be as open as we can and allow people access to their personal information. Where we hold your personal data, you can make a ‘subject access request’ to us and we will provide you with:
- a description of it
- an explanation of why we are holding it
- information about who it could be disclosed to
- a copy of the information in an intelligible form – unless an exception to the disclosure requirements is applicable.
If you would like to make a ‘subject access request’ please make it in writing to our contact email address noted in Section 2 and mark it clearly as ‘Subject Access Request’.
If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.
Unless you agree a different time, we will complete your subject access request within one month.
Right to stop marketing messages
You always have the right to stop marketing messages. We will usually include an unsubscribe button in any marketing emails. If you do wish to unsubscribe, please just click the unsubscribe button and we will promptly action that request. Alternatively, you can update your marketing preferences by contacting us at any time. Our contact details are shown in Section 2.
Right to be forgotten
If we hold personal data about you, but it is no longer necessary for the purposes that it was collected and cannot otherwise be justified – you have the right to request that we delete the data.
Right to restrict data
If we hold personal data about you and you believe it is inaccurate you have the right to request us to restrict the data until it is verified. You also have the right to request that the data is restricted where you have a right to it being deleted but would prefer that it is restricted.
Transferring your personal data
Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with your contract, as set out under section 4 How we use your personal information, you may ask us to provide you with a copy of that information in a structured data file. We will provide this to you electronically in a structured, commonly used and machine-readable form, such as a CSV file.
You can ask us to send your personal information directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information
Right to complain
You always have the right to complain to the personal data regulator, the ICO. You may also be entitled to seek compensation if there has been a breach of data protection laws.
Section 9 – Policy updates
This policy was last updated on October 14th 2021.