Apollo Multi Asset Management LLP is committed to ensuring the privacy of our clients and other people that we have dealings with. In this policy we explain how we hold, process and retain your personal data.
1.1 This section provides you with information about:
a) what personal data we hold and process;
b) in respect of personal data that we did not collect from you directly, where we obtained that data from, and what types of data we have collected;
c) he purposes for which we may process your personal data; and
d) the legal grounds on which we process your data.
1.2 Contact data. We may process contact details that you provide to us (“contact data”). This contact data may include your name, address, telephone number, and email address, and will be provided by you verbally or through our websites. We may use this contact data to contact you to discuss your relationship with our firm and its products, and how we performed and functioned for you. The legal basis for this processing is our legitimate interest in ensuring the efficient administration and continued function of our services.
1.3 Profile Data. During the course of providing services to you, you may provide us with biographical information about yourself (“profile data”). This profile data may include your date of birth, marital status, home address, length of residence in the UK or regulatory authorisations and approvals.
We may use this data to meet our legal requirements with regards to Anti Money Laundering, Terrorist Financing and Anti Bribery obligations that are imposed upon us.
We will not use this data for the purposes of carrying out marketing activities, specifically in order to tailor the offers, advertisements and promotions that we bring to your attention when we contact you.
1.5 Website data. We may process data about your use of our website and services (“website data”). The website data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the website data is our analytics tracking system. This website data may be processed for the purposes of analysing the use of the website and services.
The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
1.6 Enquiry data. We may process information contained in any enquiry you submit to us regarding our products or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you.
The legal basis for this processing in this way is for the purposes of performing our contract with you, or in taking steps at your request prior to entering into a contract.
1.7 Notification data. We may process information that you provide to us for the purpose of subscribing to our newsletters etc (“notification data”). The notification data may be processed for the purposes of sending you newsletters but we will not do this without firstr having received your consdent.
The legal basis for this processing is consent.
1.8 Correspondence data. We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content associated with the communication.. The correspondence data may be processed for the purposes of communicating with you and record-keeping.
The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
1.9 Other processing activities. In addition to the specific purposes for which we may process your personal data set out above, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
Please do not supply any other person’s personal data to us, unless we prompt you to do so or have entered into a written data processing agreement with you.
2.1 We do not supply your personal data to other parties
3.1 Where your personal data is transferred outside of the EEA, we will ensure that either (a) The European Commission has made an “adequacy decision” with respect to the data protection laws of the country to which it is transferred, or (b) we have entered into a suitable data processing agreement with the third party situated in that country to ensure the adequate protection of your data. In all cases, transfers outside of the EEA will be protected by appropriate safeguards.
4.1 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. However, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, for our legitimate interests, or in order to protect your vital interests or the vital interests of another natural person.
5.1 We may update this policy from time to time by publishing a new version on our website.
5.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
5.3 We may notify you of changes to this policy by email.
6.1 You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
a) your request not being found to be unfounded or excessive, in which case a charge may apply; and
b) the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).
6.2 We may withhold personal information that you request to the extent permitted by law.
6.3 You may instruct us at any time not to process your personal information for marketing purposes.
6.4 In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
6.5 The rights you have under data protection law are:
a) the right to access;
b) the right to rectification;
c) the right to erasure;
d) the right to restrict processing;
e) the right to object to processing;
f) the right to data portability;
g) the right to complain to a supervisory authority; and
h) the right to withdraw consent.
6.6 Your right to access your data. You have the right to ask us to confirm whether or not we process your personal data and, to have access to the personal data, and any additional information. That additional information includes the purposes for which we process your data, the categories of personal data we hold and the recipients of that personal data. You may request a copy of your personal data. The first copy will be provided free of charge, but we may charge a reasonable fee for additional copies.
6.7 Your right to rectification. If we hold any inaccurate personal data about you, you have the right to have these inaccuracies rectified. Where necessary for the purposes of the processing, you also have the right to have any incomplete personal data about you completed.
6.8 Your right to erasure. In certain circumstances you have the right to have personal data that we hold about you erased. This will be done without undue delay. These circumstances include the following: it is no longer necessary for us to hold those personal data in relation to the purposes for which they were originally collected or otherwise processed; you withdraw your consent to any processing which requires consent; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. We will analyse each request for erasure and we will agree if there is no legitimate reason to retain the data to the normal retention period, at which point we will instruct anonymization of the data.
6.9 Your right to restrict processing. In certain circumstances you have the right for the processing of your personal data to be restricted. This is the case where: you do not think that the personal data we hold about you is accurate; your data is being processed unlawfully, but you do not want your data to be erased; it is no longer necessary for us to hold your personal data for the purposes of our processing, but you still require that personal data in relation to a legal claim; and you have objected to processing, and are waiting for that objection to be verified. Where processing has been restricted for one of these reasons, we may continue to store your personal data. However, we will only process it for other reasons: with your consent; in relation to a legal claim; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
6.10 Your right to object to processing. You can object to us processing your personal data on grounds relating to your particular situation, but only as far as our legal basis for the processing is that it is necessary for: the performance of a task carried out in the public interest, or in the exercise of any official authority vested in us; or the purposes of our legitimate interests or those of a third party. If you make an objection, we will stop processing your personal information unless we are able to: demonstrate compelling legitimate grounds for the processing, and that these legitimate grounds override your interests, rights and freedoms; or the processing is in relation to a legal claim.
6.11 Your right to object to direct marketing. You can object to us processing your personal data for direct marketing purposes. If you make an objection, we will stop processing your personal data for this purpose.
6.12 Your right to data portability. Where you have given us consent to process your personal data for the performance of a contract, you have a legal right to receive a copy of the personal data we hold about you. We will not be accepting Data Portability files from other third-party companies/individuals. When a data request is made of us we will make available all applicable personal data to you in a .CSV file or alternative machine-readable format agreed by us to be passed to the appropriate third party on your instruction. We will not however process your data in this way if we believe that it may pose a threat to the security of the data.
6.13 Your right to object for statistical purposes. You can object to us processing your personal data for statistical purposes on grounds relating to your particular situation, unless the processing is necessary for performing a task carried out for reasons of public interest.
6.14 Complaining to a supervisory authority. If you think that our processing of your personal data infringes data protection laws, you can lodge a complaint with a supervisory authority responsible for data protection. You may do this in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
6.15 Right to withdraw consent. To the extent that the legal basis we are relying on for processing your personal data is consent, you are entitled to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
6.16 Exercising your rights. You may exercise any of your rights in relation to your personal data by written notice to us in addition to the other methods specified above.
Visitors to our websites
When someone visits our site we collect standard internet log inform ation and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. We collect this information in a way which does not identify anyone. We will not associate any data gathered from this site with any personally identifying information from any source. We will make it clear when we collect personal information and will explain what we intend to do with it.
Our use of cookies
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.
To opt out of being tracked by Google Analytics across all websites visit tools.google.com/dlpage/gaoptout.
Service Activity Logging
Our application has the capability to monitor your actions while using our service. We use this information to understand the use of our services, to diagnose problems and enhance the features and functionality of our service.
Exceptions
Except as described above, we will not otherwise use or disclose any personally identifiable client information, except to the extent reasonably necessary: –
To correct technical problems and to technically process your information
To protect the security and integrity of the web site and our service
To protect our rights and property and the rights and property of others
To take precautions against liability
To respond to claims that your information violates the rights or interests of third parties
To the extent required by law or to respond to judicial process or
To the extent permitted under other provisions of law, to provide information to law enforcement agencies or for an investigation on a matter related to public safety, as applicable
You understand and agree that technical processing of your information is and may be required (a) to send and receive messages in your use of the Service; (b) to conform to the technical requirements of connecting networks; (c) to conform to the limitations of our Service; and (d) to conform to other, similar technical requirements.
8.1 This website is owned and operated by Apollo Multi Asset Management LLP.
8.2 We are registered in England and Wales under registration number OC339180, and our registered office is at Chart House, Effingham Road, Reigate, Surrey, RH2 7JN, and we are registered by the Financial Conduct Authority under Firm Reference Number 487458.
8.3 You can contact us:
a) by post, at Castle Court, 41 London Road, Reigate, Surrey RH2 9RJ
b) using our website contact form;
c) by telephone, on the contact number published on our website from time to time; or
d) by email, using the email address published on our website from time to time.
Our data protection officer’s contact details are: Trevor Wells who can be contacted on telephone: 020 3301 9331.
Marketing Communication. The value of an investment and the income from it can fall as well as rise and you may not get back the amount originally invested.
Integrity in decision-making
Issued by Apollo Multi Asset Management LLP. Authorised and regulated by the Financial Conduct Authority
