Legal & Privacy
Privacy Policy
Our website at www.fundpath.com and application are provided by Fundpath Limited of 73 Cornhill, London, United Kingdom, EC3V 3QQ, registered in England with company number 13149550 (we, our, or us). We are registered with the Information Commissioner’s Office with registration ZB122158.
Fundpath is the “controller” of personal data obtained via our website and application (“app”), meaning we are the organisation legally responsible for deciding how and for what purposes it is used. We take your privacy very seriously and we are committed to ensuring that your privacy is protected.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 (DPA 2018) and the Privacy and Electronic Communications Regulation 2003 (PECR 2003), and other domestic legislation relating to the processing of personal data as they may be enacted, amended, replaced or repealed from time to time.
Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our website and app. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint or would like to limit the use of the personal data we hold about you.
Given the nature of our website and app, we do not expect to collect the personal data of anyone under 13 years old. If you are aware that any personal data of anyone under 13 years old has been shared with our app or website please let us know so that we can delete that data.
If you would like to view this policy in another format (for example audio, large print) please contact us (see the ‘HOW TO CONTACT US’ section).
This privacy policy is broken down into the following sections:
- WHAT DOES THIS POLICY APPLY TO?
- WHAT IS THE PERSONAL DATA WE COLLECT ABOUT YOU?
- HOW DO WE COLLECT YOUR PERSONAL DATA?
- HOW AND WHY DO WE USE YOUR PERSONAL DATA?
- FUNDPATH MARKETING
- WHO WE SHARE YOUR PERSONAL DATA WITH
- HOW LONG WILL YOUR PERSONAL DATA WILL BE KEPT BY FUNDPATH?
- TRANSFERRING YOUR PERSONAL DATA OUT OF THE UK AND EEA
- COOKIES AND TRACKING TECHNOLOGIES
- WHAT ARE YOUR RIGHTS?
- HOW IS YOUR PERSONAL DATA KEPT SECURE?
- How DO YOU COMPLAIN?
- CHANGES TO THIS PRIVACY POLICY
- HOW TO CONTACT US
1. WHAT DOES THIS POLICY APPLY TO?
This privacy policy relates to your use of our website and the Fundpath application.
Throughout our website or app we may link to other websites owned and operated by certain trusted third parties. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control those third-party websites and are not responsible for their privacy statements and policies. When you leave our website, we encourage you to read the privacy policy of every website you visit.
2. WHAT IS THE PERSONAL DATA WE COLLECT ABOUT YOU?
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). The personal data we collect about you depends on the particular activities carried out through our website and application. We will collect and use the following personal data about you:
- your name, address and contact information, including email address and telephone number;
- information to check and verify your identity, e.g. date of birth;
- your gender, if you choose to give this to us;
- location data;
- relevant employment data and history, and any other information you provide on your application profile;
- details of any information, feedback or other matters you give us by phone, email, post or via social media;
- your account details, such as username and login details;
- your activities on, and use of, our website;
- your personal interests;
- information about the services we provide to you;
- your contact history;
- information about how you use our website and technology systems; and
- your responses to surveys, competitions and promotions.
If you do not provide personal data we ask for where it is requested from you, it may delay or prevent us from providing services to you.
We collect and use this personal data for the purposes described in the ‘HOW AND WHY DO WE USE YOUR PERSONAL DATA’ section.
3. HOW DO WE COLLECT YOUR PERSONAL DATA?
We collect personal data from you directly, when you enter or send us information; access our website; use our app; complete any forms and/or enquiries on out website; take part in surveys or competitions; submit reviews; and indirectly using the technologies explained in the section on ‘COOKIES AND TRACKING TECHNOLOGIES’.
We also collect personal data (limited to business information only) on a legitimate interests basis from public sources, including LinkedIn, companies’ external websites and trade media.
4. HOW AND WHY DO WE USE YOUR PERSONAL DATA?
Under data protection law, we can only use your personal data if we have a proper reason, e.g: with your consent, for example when you sign up to the Fundpath app and input data; to comply with our legal and regulatory obligations; for the performance of a contract with you; or for our legitimate interests or those of a third party, for example where we collect publicly available data.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.
You can obtain details of this assessment by contacting us – see the ‘HOW TO CONTACT US’ section.
The table below explains what we use your personal data for and why.
What we use your personal data for | Our reasons |
To create and manage your account with us | We will create your account on the Fundpath App with your consent and the information which you submit. |
To update our database with publicly available information | For our legitimate business interests in providing the best service and quality for users of our Fundpath App. We match professionals using this information and technology. Please see a summary of your rights in relation to automated decision making below. |
Providing services to you | To perform our contract with you or to take steps at your request before entering into a contract |
Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us | Depending on the circumstances:
-To comply with our legal and regulatory obligations -For our legitimate interests or those of a third party, i.e. to minimise fraud that could be damaging for you and/or us |
To enforce legal rights or defend or undertake legal proceedings | Depending on the circumstances:
—to comply with our legal and regulatory obligations —in other cases, for our legitimate interests or those of a third party, i.e. to protect our business, interests and rights or those of others |
Customise our website and its content to your particular preferences based on a record of your selected preferences or on your use of our website | Depending on the circumstances:
—your consent as gathered by the separate cookies tool on our website —see the section on “COOKIES AND TRACKING TECHNOLOGIES” —where we are not required to obtain your consent and do not do so, for our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you. |
Retaining and evaluating information on your recent visits to our website and how you move around different sections of our website for analytics purposes. This helps us to understand how people use our website so that we can make it more intuitive or to check our website is working as intended | Depending on the circumstances:
—your consent as gathered by the separate cookies tool on our website —see the section on “COOKIES AND TRACKING TECHNOLOGIES” —where we are not required to obtain your consent and do not do so, for our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you. |
Communications with you not related to marketing, including about changes to our terms or policies or changes to the services or other important notices | Depending on the circumstances:
—to comply with our legal and regulatory obligations —for performance of our contract —in other cases, for our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you. |
Protecting the security of systems and data | To comply with our legal and regulatory obligations
We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests or those of a third party, i.e. to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us |
Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base or other efficiency measures | For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you at the best price |
Updating and enhancing customer and lead data records | Depending on the circumstances:
—to perform our contract with you or to take steps at your request before entering into a contract —to comply with our legal and regulatory obligations —where neither of the above apply, for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders |
Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, e.g. to record and demonstrate evidence of your consents where relevant | To comply with our legal and regulatory obligations |
Marketing our services to existing and former customers by email and via the Fundpath app push notifications. | With your consent, or otherwise for our legitimate interests where you have used .
See the ‘FUNDPATH MARKETING’ section for further information |
External audits and quality checks, e.g. for the audit of our accounts | For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards |
To share your personal data with members of our group and third parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency
In such cases information will be anonymised where possible and only shared where necessary |
Depending on the circumstances:
—to comply with our legal and regulatory obligations —in other cases, for our legitimate interests or those of a third party, i.e. to protect, realise or grow the value in our business and assets |
Where we need to collect personal data by law or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you.
See the ‘WHO WE SHARE YOUR PERSONAL DATA WITH?’ section of the policy for further information on the steps we will take to protect your personal data where we need to share it with others.
5. FUNDPATH MARKETING
We may use your personal data to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.
We will obtain your consent marketing purposes (see the ‘HOW AND WHY DO WE USE YOUR PERSONAL DATA?’ section). We will also ask for you to consent to push notifications within our app.
Sometimes, we will rely on ‘soft opt in’ which means we don’t need your consent to market certain services to you, but only when it is lawful for us to do so.
You have the right to opt out of receiving marketing communications at any time by:
contacting us at gdpr@fundpath.com ; or
- using the ‘unsubscribe’ link in emails.
We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal data with the utmost respect and never sell your data for marketing purposes.
For more information on your right to object at any time to your personal data being used for marketing purposes, see the ‘WHAT ARE YOUR RIGHTS?’ section.
6. WHO WE SHARE YOUR PERSONAL DATA WITH
We routinely share personal data with:
- trusted third parties we use to help deliver our services to you, e.g. asset managers, IT providers and payment service providers;
- other third parties we use to help us run our business, e.g. asset managers, marketing agencies or website hosts and website analytics providers;
- our banks and any banks that we may work with.
We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.
We or the third parties mentioned above may occasionally also need to share personal data with:
- external auditors, e.g. in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations;
- professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;
- law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations; and
- other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations.
If you would like more information about who we share our data with and why, please contact us (see the ‘HOW TO CONTACT US’ section).
7. HOW LONG WILL YOUR PERSONAL DATA WILL BE KEPT BY FUNDPATH?
We will not keep your personal data for longer than we need it for the purpose for which it is used, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements.
Different retention periods apply for different types of personal data. 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.
Following the end of the of the relevant retention period, we will delete or anonymise your personal data (so that it can no longer be associated with you).
8. TRANSFERRING YOUR PERSONAL DATA OUT OF THE UK AND EEA
The EEA, UK and other countries outside the EEA and the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.
It is sometimes necessary for us to share your personal data to countries outside the UK and EEA. In those cases we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.
Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA or to an international organisation where:
- in the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR;
- in the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’) further to Article 45 of the EU GDPR;
- there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or
- a specific exception applies under relevant data protection law.
Where we transfer your personal data outside the UK we do so on the basis of an adequacy regulation or (where such is not available) the use of Standard Contractual Clauses (SCCs).
For further information about such transfers and the safeguards we employ, please contact us (see the ‘HOW TO CONTACT US’ section).
9. COOKIES AND TRACKING TECHNOLOGIES
A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our website. We use cookies and tracking technologies on our website with your consent. Specifically, we use a Salesforce Pardot cookie to gather information about how people use our website.
These help us recognise you and your device and store some information about your preferences or past actions, as set out in the HOW AND WHY DO WE USE YOUR PERSONAL DATA? Section.
10. WHAT ARE YOUR RIGHTS?
You generally have the following rights, which you can usually exercise free of charge*:
Access to a copy of your personal data | The right to be provided with a copy of your personal data.
This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. If we agree that we are obliged to provide personal information to you (or someone else on your behalf), we will provide it to you or them free of charge and aim to do so within 30 days from when your identity has been confirmed. We would ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information. |
Correction (also known as rectification) | The right to require us to correct any mistakes in your personal data. 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.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if any of the details you provide to us should change, during the course of your relationship with us. |
Erasure (also known as the right to be forgotten) | The right to require us to delete your personal data—in certain situations.
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, within one month of your request. |
Restriction of use | The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data or where our use of the data is unlawful but you do not want us to erase it. |
Data portability | The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations. |
To object to use | The right to object:
—at any time to your personal data being used for direct marketing (including profiling); and —in certain other situations to our continued use of your personal data, e.g. where we use your personal data for our legitimate interests. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. |
Not to be subject to decisions without human involvement | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. |
Withdraw consent at any time | This right can be used where we are relying on consent to process your personal data.
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. |
For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘HOW TO CONTACT US’). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR, such as via the https://ico.org.uk/.
If you would like to exercise any of those rights, please email, call or write to us—see: ‘HOW TO CONTACT US’. When contacting us please:
- provide enough information to identify yourself such as your full name, address and reference number and any additional identity information we may reasonably request from you; and
- let us know which right(s) set out in the table able that you want to exercise and the information to which your request relates.
*You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month (up to three months) if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
11. HOW IS YOUR PERSONAL DATA KEPT SECURE?
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
12. HOW DO YOU COMPLAIN?
Please contact us if you have any queries or concerns about our use of your information (see the section ‘HOW TO CONTACT US’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with:
- the Information Commissioner in the UK; and
- a relevant data protection supervisory authority in the EEA state of your habitual residence, place of work or of an alleged infringement of data protection laws in the EEA.
The UK’s Information Commissioner may be contacted at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
13. CHANGES TO THIS PRIVACY POLICY
We keep this Privacy Policy under regular review. Historic versions can be obtained by contacting us. We may therefore change this privacy policy from time to time—when we make significant changes we will take steps to inform you.
14. HOW TO CONTACT US
You can contact us and/or our Data Protection Lead by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
Fundpath Limited, 73 Cornhill, London, United Kingdom, EC3V 3QQ