This notice describes how Thornbridge Investment Management (Thornbridge) uses personal data. It outlines Thornbridge’s data protection obligations and your data protection rights under the General Data Protection Regulation 2018 (“GDPR”).
Thornbridge Investment Management LLP is the data controller of your personal information, and this policy applies to the processing of activities by us.
Collection of your data
As part of providing our services, or information about our services, to you, and to ensure we do this in a compliant way, under the authorisation of our regulator and the General Data Protection Regulation, we must collect some personal information from our clients, potential clients, visitors to our website and service providers or suppliers. This may include third parties carrying out credit or identity checks on our behalf. The credit search is required to adhere to money laundering regulations.
We may collect your name and contact details (such as your email address, phone number or address) in order to send you information about our products and services which you might have expressed interest in. We may collect this directly from you, or through a third party. If a third party collected your name and contact details, they will only pass those details to us for marketing purposes if you have consented to them doing so. It is in our legitimate interest to use your personal information in such way. If you do not wish to receive this information, please contact us by emailing email@example.com or by writing to us at the following address:
Data Protection Officer
Thornbridge Investment Management LLP
13 Austin Friars
Our web pages and emails may contain; cookies, web beacons or pixel tags or any other similar type of data analysis tools which allow us to track receipt of correspondence and to count the number of users that have visited our webpage or opened our correspondence.
We may collect the following types of information from actual or potential customers:
- Your full name, address and contact information including but not limited to phone number and email address;
- Your date of birth and gender;
- Your professional and employment details;
- Your identification details such as your passport or driver’s licence;
- Proof of address such as a bank statement or utility bill;
- Your national insurance or tax identification number;
- Criminal convictions data
- Corporate information;
- Information about your income or the source of your funds and wealth including details about your assets and liabilities;
- Your trading experience and transaction history;
- Financial information including investment portfolio details, income levels, taxation details;
- Information regarding relationships you have with banks and/or other financial institutions (including bank details);
We obtain this information through your use of our services or our websites, the onboarding process and from information provided in the course of ongoing customer communication.
This information is held by us on servers based in the United Kingdom. When you interact with our services, our servers keep an activity log unique to you that collects certain administrative and traffic information including: the source of your IP address, the time of access, the date of access and the web pages you visited. We need this information to provide you with our services.
We are required to collect information about visitors to our premises. We may record information if your visit us such as your name, the date and time you arrived and left, who you are visited, your firm or employer name and your contact details.
We may record any communications, email, electronic, by telephone, in person or otherwise, that we have with you in relation to the services we provide to you and our relationship with you. These recordings will be our sole property and constitute evidence of the communications between us. Any telephone conversation may be recorded without the use of a warning tone or any other further notice.
We take care to ensure your personal information is safe, secure and is protected from misuse, interference, unauthorised access, loss, modification or disclosure. Your personal information is generally stored in our computer database. Any paper-based information is stored in secure areas. In relation to information that is held on our computer database, we apply the following guidelines:
- passwords are required to access the system and passwords are routinely checked and are not shared;
- data ownership is clearly defined and data is only held where necessary;
- employees have restricted access to certain sections of the system;
- the system automatically logs and reviews all unauthorised access attempts;
- unauthorised employees are barred from updating and editing personal information;
- all computers which contain personal information are secured both physically and electronically;
- data is encrypted during transmission over the network; and
- print reporting of data containing personal information is limited.
We train our employees who handle personal information to respect the confidentiality of customer information and the privacy of individuals. We regard breaches of your privacy very seriously and will impose appropriate penalties where necessary.
When we consider that personal information is no longer needed, we will remove any details that will identify you or we will securely destroy the records. We may need to hold some information and maintain certain records for up to 7 years after the end of us providing services to you. This is because we are subject to regulatory requirements and anti-money laundering laws which require us to retain;
- Account opening forms and any documents used to comply for customer due diligence obligations; and
- Supporting evidence and records of trades and transactions with you.
- Details of your communications and relationship with us, for a period of seven years after our business relationship with you has ended.
Collection of personal information
We may be required to disclose your personal information if requested to do so by law, or if we believe in good faith that such action is necessary;
- to comply with any legal process served on us or in circumstances where we are under a similar legal or regulatory obligation;
- to protect and defend our rights or property; or
- to act to protect the personal safety of users of the services or the public. If, in our sole determination, you are found to have cheated or attempted to defraud us, our Affiliates, or any other user of the Services in any way including, but not limited to, market or price manipulation, payment fraud, including use of stolen credit cards, or any other fraudulent activity (including any chargeback or other reversal of a payment) or prohibited transaction (including money laundering).
Where required to disclose information we reserve the right to share information, together with your identity with other financial services providers, banks, credit card companies, and appropriate regulatory and legal agencies.
Transfer of personal data abroad
We may on occasion need to transfer some of your information to other group companies or service providers in countries in or outside the EEA (European Economic Area). This may happen if our servers or suppliers and service providers are located elsewhere. When we transfer your personal data outside the EEA, we will ensure the data recipient is subject to the same data requirements under GDPR. By using our services and providing us with your information, you consent to the collection, transfer, storage and processing of your information outside of the EEA.
Your personal data rights
- You have the right to be informed,
- You have the right to check what personal information is held by us, at no cost,
- You have the right to have wrongly recorded data amended,
- You have the right to “be forgotten” I.e the removal of your data,
- You have the right to “Opt out”
- You have the right to object to the processing of your personal information,
- You have the right to request the restriction of the processing of your personal information,
- You have the right to request the transfer of your personal information,
You have the right to withdraw your consent.
Concerns or complaints
If you are concerned about us any aspect of our conduct regarding your privacy, you can make a complaint. We will act upon it promptly. To make a complaint, please e-mail us at firstname.lastname@example.org We will respond and address, without delay, any request, question, complaint or enquiry you have about your personal information or our conduct in processing it. If you are not satisfied with the way we handled your response, or you believe we have not adequately resolved a matter, you have the right to complain to the Information Commissioner’s Officer (the ‘ICO’). You can find further details on the ICO website at https://ico.org.uk/
You also have the right, at any time, to complain to the Information Commissioner’s Office. As an independent UK authority, the ICO upholds information rights in the public interest, promotes openness by public bodies and data privacy for individuals.
Thornbridge Investment Management LLP is registered with the Information Commissioner’s Office, registration number ZA178531. We can be contacted at
Thornbridge Investment Management LLP
13 Austin Friars
Cookies consist of small files, often including unique identifiers, that are sent by web servers to web browsers, and which may then be sent back to the server each time the browser requests a page from the server.
Cookies can be used by web servers to identity and track users as they navigate different pages on a website and to identify users returning to a website.
Cookies may be either “persistent” cookies or “session” cookies. A persistent cookie consists of a text file sent by a web server to a web browser, which will be stored by the browser and will remain valid until its set expiry date (unless deleted by the user before the expiry date). A session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Cookies on this website
We use both session cookies and persistent cookies on this website.
Cookies do not contain any information that personally identifies you, but personal information that we store about you may be linked, by us, to the information stored in and obtained from cookies.
We may use the information we obtain from your use of our cookies for the following purposes:
- to recognise your computer when you visit our website;
- to track you as you navigate our website, and to enable the use of the some of the features on our website;
- to improve the website’s usability;
- to analyse the use of our website;
- in the administration of this website;
- to personalise content on our website for you.
Third party cookies
Most browsers allow you to refuse to accept cookies. For example:
- in Internet Explorer you can refuse all cookies by clicking “Tools”, “Internet Options”, “Privacy”, and selecting “Block all cookies” using the sliding selector;
- in Firefox you can block all cookies by clicking “Tools”, “Options”, and un-checking “Accept cookies from sites” in the “Privacy” box.
Blocking all cookies will, however, have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use many of the features of this website.
You can also delete cookies already stored on your computer. The method of doing so will depend upon your web browser. Instructions are available at the following URLs.
Internet Explorer: http://support.microsoft.com