Harrington Cooper LLP seeks to protect the privacy of all personal data in its procession in compliance with the General Data Protection Regulation (GDPR). For the purposes of the GDPR Harrington Cooper is both a data controller and data processor. We show below our policies regarding the collection, use and transfer of personal data together with the actions we take to protect such data. We also indicate your rights and options with regard to the access or use of this data.
We reserve the right to revise this policy from time to time to ensure it always complies with current regulatory and legislative requirements so please revisit this page periodically. Any questions regarding this Policy may be emailed to firstname.lastname@example.org.
Who are we?
Harrington Cooper works with a small handful of asset managers to provide cross-border distribution services. We also establish asset managers in new markets and facilitate their global expansion.
How do we collect information from you?
We generally obtain information about you from business cards provided at meetings or on other occasions, details given over the phone and requests received by email or via our website. We may also collect information from publicly-available sources where you have provided your consent to share information.
What type of personal data is collected?
Typically the personal information we collect will include one or more of the following;
Your name, business address, email address, IP address, telephone numbers and information regarding which webpages have been accessed. We may also make notes of conversations we have with you to better tailor our service to your requirements.
How is your information processed?
We use your information to make you aware of investment products that we consider may be appropriate for your business or that of your clients and to keep you informed on investment products we believe are held by you or your clients. The GDPR permits us to do this as part of the legitimate interest assessment we have undertaken which includes a requirement for us to seek to understand the needs of our contacts and clients and provide the highest possible levels of service.
What is the legal basis for processing personal data?
We have undertaken a Legitimate Interests Assessment and have concluded that, on balance, the legitimate Interests of ourselves and you, the data subjects we contact, are not undermined by adopting this legal basis for such processing in place of any other alternative option. Where we are processing your data on the basis of legitimate interests you can request us to stop doing so. We must then cease such processing unless we believe we have a legitimate overriding reason to continue processing your personal data such as a regulatory or legal requirement.
Your rights relating to the personal data held by us
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data: –
- The right to request a copy of your personal data which Harrington Cooper LLPholds about you;
- The right to request that the Harrington Cooper LLPcorrects any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer appropriate for Harrington Cooper LLPto retain such data;
- The right to withdraw your consent to the processing of personal data at any time;
- The right to request that Harrington Cooper LLPprovides you, the data subject, with your personal data;
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- The right to lodge a complaint with the Information Commissioners Office.
You have the right to stop the use by us of your personal data for direct marketing however undertaken. We must always comply with your request.
How can you stop the use of your data for direct marketing?
Click the ‘unsubscribe’ link in any email communication that we send you.
If we wish to use your personal data for a new purpose, not covered by this Data Protection Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing. Unless we have identified a legitimate interest or you have given prior consent, we will not contact you in relation to any new purposes by email or phone.
Retention of personal data
We regularly review our retention periods for personal data and monitor we are complying with applicable guidance. We are legally required to hold some types of information to fulfil our regulatory and legal obligations. In general we will hold your personal information on our systems only for as long as is considered necessary for the relevant activity.
Who has access to your information?
We will never sell or otherwise provide your information to third parties without your express consent.
How you can access and update your information, make a complaint or exercise any other rights
To exercise all relevant rights, or if you have any queries or complaints please email us at email@example.com.
We make every effort to ensure that your personal information held by us is secure. However, we cannot guarantee the security of any information you transmit to us is totally secure as the transmission system used will not be under our control and you thus if you provide us with information you do so at your own risk.
We may analyse your personal information to create a profile of your interests and preferences so that we can contact you with information relevant to you. We may make use of additional information about you when it is available from external sources to help us do this effectively.
Transferring your information outside of Europe
The information you provide to us may be transferred to countries outside the European Union. Although such countries may not have similar data protection laws to the EU we will take all necessary action to ensure that appropriate measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this Policy.
Review of this Policy
This Policy is kept under periodic review and was last updated in May 2018.