ST PAULS MARKETING LIMITED
The privacy notice of St Pauls Marketing Limited (“the Company” or “we”) notice covers the collection, use and disclosure of personal information relating to living individuals (a “data subject” or “you”) which may be collected by the Company, such as when you visit our website or when you call us.
Please take a moment to read the following to learn more about our information practices, including what type of information is gathered, how the information is used and for what purposes, to whom we disclose the information, and how we safeguard your personal information.
Basis for processing your data
Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information are:
(a) Your consent. You are able to remove your consent at any time. You can do this by contacting us;
(b) We have a contractual obligation.
(c) We have a legal obligation.
(d) We have a vital interest.
(e) We need it to perform a public task.
(f) We have a legitimate interest.
What we do with the information we have
We use the information that you have given us in order to:
- provide information about investments and other products and services which may be of interest to you;
- check that certain promotions are suitable for you;
- inform you of news or developments regarding investments and other products and services about which we have previously communicated with you.
We may share this information with:
- providers of investments and other products and services which we promote and their authorised representatives for the purposes of communicating with you regarding the investments and other products and services in which you have expressed an interest;
- our directors and officers, employees, consultants and contractors for the purpose only of facilitating the operation of our website and carrying on our business;
- competent persons for legal and regulatory purposes;
- providers of investments and other products and services which we believe may be of interest to you based on the information we possess regarding your interests;
- bona fide purchasers of the whole or part of our business.
How we store your information
Your information is securely stored according to industry standards.
How long we keep your information
We keep your personal information for only as long as necessary, which is longer in some cases than in others. The length of this retention period depends on the purpose for which the data was obtained and its nature. For example:
We need to keep some personal information about you so we can deal with any complaints you might make about the products and services we provide to you;
if you ask us to stop processing your personal information for direct marketing, we need to retain enough information about you to enable us to ensure we stop including you in those direct marketing activities;
We need to keep personal information so we can defend possible future legal claims. Unless there is some other reason for keeping it, personal information will be deleted when such a claim could no longer arise or it is no longer required in order to defend legal claims that have arisen.
We have a legal or regulatory duty to retain particular personal information for a certain minimum period (for example under company or tax law).
Transfer of personal information outside the United Kingdom
We may use certain third party companies to perform some functions of the products and services on our behalf or to provide services to us. These third parties are only allowed access to your information as needed to perform such functions or to provide such services. They’re not allowed to use it for any other purpose.
Some of these third party companies are located, or have servers that are located, outside the UK. Where we share your information with such companies, we take all steps reasonably necessary to ensure your information is treated securely and in accordance with this privacy notice. The data protection and other laws of such countries may not be as comprehensive as those in the UK. We will only transfer your personal information to a territory outside of the UK under the following circumstances:
- the UK legislation provides or the UK government has determined that an adequate level of protection for personal information is in place in the country to which we transfer your data;
- other appropriate safeguards have been put in place as described in the privacy notice for the applicable product/service.
Your data protection rights
Under data protection law, you have rights including:
- Your right of access – You have the right to ask us for copies of your personal information.
- Your right to rectification – You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
- Your right to restriction of processing – You have the right to ask us to restrict the processing of your information in certain circumstances.
- Your right to object to processing – You have the right to object to the processing of your personal data in certain circumstances.
- Your right to data portability – You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
Please contact us if you wish to make a request.
As is true of most websites, we gather certain information automatically and store it in log files. This information includes Internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data.
We use this information, which does not identify individual users, to analyse trends, to administer the site, to track users’ movements around the site and to gather demographic information about our user base as a whole. The Company will not use the information collected to market directly to that person.
In some of our email messages we use a “click-through URL” linked to content on the Company’s website. When a you click one of these URLs, they pass through our web server before arriving at the destination web page. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our communications. If you prefer not to be tracked simply avoid clicking text or graphic links in the email.
In addition we use pixel tags – tiny graphic images – to tell us what parts of our website customers have visited or to measure the effectiveness of searches customers perform on our site.
Pixel tags also enable us to send email messages in a format customers can read. And they tell us whether emails have been opened to assure that we’re only sending messages that are of interest to our customers. We may use this information to reduce or eliminate messages sent to a customer.
This site uses different types of cookie.
The information generated by the cookie about your use of our website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of our website, compiling reports on website activity and providing other services relating to website activity and internet usage.
Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google undertakes not to associate your IP address with any other data held by Google.
You can opt-opt of all Google usage of cookies as stated on the Google Help page or by visiting Network Advertising Initiative Opt-Out Page
If you have Adobe Flash installed on your computer and you use the Site’s audio or video players, Google Analytics will try to store some additional data on your computer. This data is known as a Local Shared Object or Flash cookie. This helps us to analyse the popularity of our media files. We can count the total number of times each file is played, how many people watch videos right to the end and how many people give up half way through. Adobe’s website offers tools to control Flash cookies on your computer.
Blocking or removing Cookies – More Information
Some third party cookies are set by services that appear on our pages. They are set by the operators of that service and are not in our control. They are set by Twitter, Facebook and inShare and relate to the ability of users to share content on this site, as indicated by their icons.
If you want to delete any cookies that are already on your computer, please refer to the instructions for your file management software to locate the file or directory that stores cookies. You can access them through some types of browser. Search in your cookie folders or in your browser preferences if you wish to delete them.
More information about cookies, including how to block them or delete them, can be found at AboutCookies.org
Our commitment to you
The Company’s website may have links to the sites of other companies. We are is not responsible for their privacy practices. We encourage you to learn about the privacy policies of those companies.
If you have questions or concerns about this Privacy notice or data processing, please contact us at:
Post: Data Protection manager
St Pauls Marketing Limited
124 City Road, London, United Kingdom, EC1V 2NX
If you notify us that you do not want us to use your information for a particular purpose, we will not do so.
We may update its privacy notice from time to time. When we change the policy in a material way a notice will be posted on our website along with the updated privacy notice.
How to complain
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office, Wycliffe House,Water Lane, Wilmslow, Cheshire, SK9 5AF.
Helpline number: 0303 123 1113