Privacy Policy

This notice sets out how Margetts Fund Management Ltd (Margetts) uses and protects your personal information.

Margetts is the Data Controller for personal data about our clients, suppliers, employees and shareholders.  We aim to hold a minimum amount of personal data in order to provide our services and we are committed to securely storing, transferring and removing your data.

We do not trade personal data for commercial purposes and will only disclose it if required by law or if we think it would be beneficial to deliver our services.  Where possible Margetts use providers based in the European Economic Area (EEA) to process your data and if this is not possible, we will make it clear.

Transfers between Margetts and third parties are securely managed under our Information Security Policy.  We will always aim to transfer the minimum amount of data necessary.

If you have any data protection queries then please contact the Data Protection Officer DataProtection@Margetts.com 0121 236 2380 or write to us Margetts Fund Management, 1 Sovereign Court, Graham Street, Birmingham B1 3JR.

Your rights

As an individual whose personal data is processed by Margetts you have the following rights:-

• The right to be informed. This notice and any separate processing notices provide that information.

• The right of access. You have the right to access the personal data and supplementary information that we hold on you.  You also have the right to verify the legality of the processing.  To exercise this right then please contact the Data Protection Officer.

• The right to rectification.  You have the right to ask us to rectify any inaccurate or incomplete information that we hold on you.  We have one calendar month to respond to your request.

• The right to erasure. You have the right to ask us to remove personal information (known as ‘the right to be forgotten’).  We have one calendar month to respond to your request.
• The right to restrict processing.  You have the right to ask us to stop processing your data.  Whilst your data may still be stored, it cannot be used.  We have one calendar month to respond to your request.
• The right of data portability. You have the right to ask for your personal data to be provided in an electronic format that can be readily used by you or other organisations.  We have one calendar month to respond to you request.
• The right to object. You have the right to object to your personal data being used for marketing, research or on the basis of legitimate interests.

• Rights related to automated decision making, including profiling. You have the right to ask that any decisions that are made automatically be reviewed through human assessment.  Margetts may use systems to verify your identity or to verify other information, should these not pass then we automatically review information through human assessment.

To exercise any of these rights or to discuss any aspect of our data processing activities, please contact us at our offices, call 0121 236 2380 or email DataProtection@Margetts.com. We may need to verify your identity to ensure your information is correctly protected.

If you are not happy with the way we have handled your data and are unable to resolve the issue with us personally, you can complain to the ICO.

Intermediaries

Registered Users

If you have acted as an intermediary for an investor then we will hold personal data on you in order to deliver our services.

The personal information we hold will have been directly gathered through:-

• Direct communication with you or your office
• Investors that have appointed you to their account
• The FCA website
• Marketing efforts
• Other direct sources

We may also have gathered supplementary information through:-

• Credit agencies
• Anti-fraud or anti-money laundering services
• The internet
• Other supplementary sources

The legal basis for processing your personal data is to negotiate or fulfil our contract and legal obligations and for legitimate interest in providing the best possible products and services.

We may transfer your information in order to provide our services or where required by law.  The following third parties are currently engaged, however the list may not be comprehensive.

Unless specified, any service we employ will be a data processor and cannot use the information transferred to them.

• Bravura Services. Bravura services provide Margetts with software to manage and store the register of investors.

• Electronic Anti-Money Laundering or Fraud Services. We may provide your personal data to third party services that help to detect, reduce or prevent fraud and money laundering.  In some cases these providers may be classed as data controllers or joint controllers of your information.  This means that they can use you data in their own right.  We carefully select partners and will only select partners that we believe will not infringe on your rights and will treat your data appropriately.

• Printing Services. We may employ companies to print documents, which may be sent to you, such as contract notes or statements.  Any service we use will act as a data processor and cannot use the information transferred to them.  The details of these suppliers are available on request, but may change without notice.

We will retain our records for a minimum of seven years after the end of the relationship with your last investor.  The end of the relationship would be after the last transaction that leaves a zero balance in the account.

Additionally, if we receive any correspondence from you following the end of the relationship, as defined above, this data may be held for a minimum of one year.

General Users

If you do not currently act for investors that use Margetts services then we may hold your personal data for marketing purposes.

The information is most likely to have been gathered through a meeting with a sales representative or as a referral from a third party.

The legal basis for processing your personal data is our legitimate interest in delivering our investment services through a diverse range of intermediaries.

We may transfer your data to services which help us to deliver our message to potential customers.  These providers will act as a data processor and will not use your personal data.

If you do not have any investors with Margetts then we will retain your information for a minimum of three years after the last correspondence with you.  If you do not wish to hear from us then you will always be given the option to opt out and we will stop processing your information.  We may need to hold some information in order to ensure that we do not send any further unsolicited communication.

Web users

Registered Users

If you are an investor or an intermediary that uses Margetts services and have registered on the website then you will have entered some personal data for us to link you to your account.  This information is used for verification and will already be stored on our systems.

Once you successfully register for our web services, personal data, including transaction histories and investment details, will be securely transferred from our main systems to our web services systems.  Our website is hosted on a dedicated server, which is not shared with third parties.  Personal data is encrypted with the exception of a small number of data points, which are required to reset passwords.

The legal basis for processing your personal data is to fulfil our contract and for legitimate interest in providing the best possible products and services.

This information will be stored for as long as you are registered on this service and remain an investor or intermediary.  For timescales about how long information is stored at the end of our relationship please see the above relevant sections.

Your email and a small amount of data may be stored on the server to maintain the integrity of the system.

Contact Form Users

If you get in touch with us via the contact form on the website, we may save the details you share with us. This way, if you get in touch with you in future we can refer to our previous conversations.

The legal basis for processing your personal data is contract and our legitimate interest in providing several avenues for contact and being able to offer coherent communication.

This information will be held for a minimum of three years if you do not become an investor in the Margetts funds, or an intermediary with investors in the Margetts funds.  If you use our services then for timescales about how long information is stored at the end of our relationship please see the above relevant sections.