We are committed to safeguarding the privacy of our website visitors.
This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
In this policy, “we”, “us” and “our” refer to Silverstripe Investment Management and its respective subsidiaries and affiliates (together “Silverstripe”). For more information about us, see Section 18.
The personal data that we collect
In this Section 2 we have set out the general categories of personal data that we process.
We may process data enabling us to get in touch with you when individuals voluntarily contact Silverstripe through the email address email@example.com listed on the website (“contact data“). The contact data may include your name, email address, telephone number, postal address and/or social media account identifiers. The source of the contact data is you and/or your employer.
Purposes of processing and legal bases
In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.
Relationships and communications – We may process contact data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and responding to your voluntary contact with Silverstripe.
Record keeping – We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
Security – We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
Legal claims – We may process your personal data where necessary for [the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
Legal compliance and vital interests – We may also process 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.
Providing your personal data to others
We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
Your personal data held in our website database will be stored on the servers of our hosting services providers.
In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure 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. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
International transfers of your personal data
In this Section 5, we provide information about the circumstances in which your personal data may be transferred to a third country under UK and/or EU data protection law.
To the extent it is necessary for Silverstripe to effect cross-border transfers of contact data, including to the United States of America and to other non EEA countries, such transfers will only be made in accordance with EU data protection laws. Transfers to these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the competent data protection authorities. For further information please contact firstname.lastname@example.org
Retaining and deleting personal data
This Section 6 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
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.
We will retain your personal data as follows:
(a) contact data will be retained for a minimum period of 1 year following the date of the most recent contact between you and us, and for a maximum period of 10 years following that date;
Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention 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.
Security of personal data
We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
We will store your personal data on secure servers, secure third-party hosted cloud infrastructure, personal computers and mobile devices, and in secure manual record-keeping systems.
You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
In this Section 8, we have listed the rights that you have under data protection law.
Your principal rights under data protection law are:
the right to access – you can ask for copies of your personal data
the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
the right to erasure – you can ask us to erase your personal data;
the right to restrict processing – you can ask us to restrict the processing of your personal data;
the right to object to processing – you can object to the processing of your personal data;
the right to data portability – you can ask that we transfer your personal data to another organisation or to you;
the right to complain to a supervisory authority – you can complain about our processing of your personal data; and
the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://edpb.europa.eu/edpb_en
You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.
Third party websites
Our website includes hyperlinks to, and details of, third party websites.
In general we have no control over, and are not responsible for, the privacy policies and practices of third parties.
Personal data of children
Our website is targeted at persons over the age of 18.
If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
Please let us know if the personal information that we hold about you needs to be corrected or updated.
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Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web 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 may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
Cookies that we use
Cookies used by our service providers
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