Privacy Policy

This is the privacy notice of Fiske plc. In this document, “we”, “our”, or “us” refer to Fiske plc and our related companies, Fieldings Investment Management Ltd.

We are company number 02248663 registered in the UK.

Our registered office is at 100 Wood Street, London, EC2V 7AN.

Introduction

1. This is a notice to inform you of our policy about all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.
2. We regret that if there are one or more points below with which you are not happy, your only recourse is to leave our website immediately.
3. We take seriously the protection of your privacy and confidentiality. We understand that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party.
4. We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
5. Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
6. The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at knowyourprivacyrights.org
7. Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.

The bases on which we process information about you

The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.

If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data. Your data will be retained according to the retention period attributed to that basis in the below paragraphs, and then destroyed.

If the basis on which we process your personal information changes then, if required by law, we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.

1. Information we process because we have a contractual obligation with you

When you buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.

In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.

We may use it in order to:

1. 1. verify your identity for security purposes
   2. sell products to you
   3. provide you with our services
   4. provide you with suggestions and advice on products, services and how to obtain the most from using our website

We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.

Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.

We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract. For some contractual matters, which may include compliance with regulatory requirements, personal information, tax authorities or other legal considerations may require us to retain the information for longer.

2. Information we process with your consent

Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, our products and services, job opportunities or you register for an event, you provide your consent to us to process information that may be personal information.

Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to the use of cookies.

Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.

We may aggregate your data in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.

If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.

We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists. We will not retain your information for more than 3 years following your last response to us.

You may withdraw your consent at any time by instructing the Data Protection Officer at: Leigh.Middleton-Ross@Fiskeplc.com. However, if you do so, you may not be able to use our website or our services further.

3. Information we process because we have a legitimate interest

Under certain conditions when there is no specific contractual agreement between us, we may process your information on the basis that it is in our legitimate business interest to do so.

These conditions could include your information being available in the public domain and our identifying, based on your job role, industry sector or location, that a product or service we offer is likely to be relevant to your interests; that you have been identified through professional networking or referred to us by a colleague or business associate as an individual who may derive value from our events, products or services; that you are a member of a firm who has previously been a client of ours and may still have interest in our products, events or services; that you have previously attended an event organised or sponsored by us.

Under these conditions we will collect and process the minimum of information about you necessary to make contact with details of the event, service or product that we believe will be of interest.

We will inform you at the point of first contact that your data is being processed in this way and you are free at any time to request no further contact by emailing Leigh.Middleton-Ross@Fiskeplc.com or replying directly to or using the relevant links in any communication we have sent you.

If you make no response to our contact, we will not continue to process your information for longer than 3 years from our first attempt. It is our policy that our email contact regarding our products and services is not excessive or unduly intrusive.

4. Information we process because we have a legal obligation

We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory or regulatory obligation.

For example, we are required to pass certain details containing personal data to HMRC to comply with tax and FATCA reporting requirements.

This may include your personal information.

Specific uses of information you provide to us

5. Information provided on the understanding that it will be shared with a third party

We use an external party to host and administer our investment management solutions.  As a result they have access to the personal data we enter into it.

Our website allows you to register to attend events. At the event, your name and company affiliation will be available to view by any other attendee of the event in the form of registration lists and ID badges.

We have no control over what any individual third party may do with this information. We accept no responsibility for their actions at any time.

No further information will be shared with any third party except with your explicit permission

6. Complaints regarding content on our website

If you complain about any of the content on our website, we shall investigate your complaint.

If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.

Free speech is a fundamental right, so we have to make a judgment as to whose right will be obstructed: yours, or that of the person who posted the content that offends you.

If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.

7. Job application and employment

If you send us information in connection with a job application, we may keep it for up to three years in case we decide to contact you at a later date.

If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for six years before pseudonymising and archiving it.

8. Sending a message to our support team

When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.

We record your request and our reply in order to increase the efficiency of our organisation.

We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.

9. Complaining

When we receive a complaint, we record all the information you have given to us.

We use that information to resolve your complaint.

If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.

We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.

10. Personal identifiers from your browsing activity

Requests by your web browser to our servers for web pages and other content on our website are recorded.

We record information such as your geographical location, your Internet service provider and your IP address.

We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.

If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.

Disclosure and sharing of your information

11. Information we obtain from third parties

Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use.

12. Credit reference

To assist in combating fraud, we share information with credit reference agencies, so far as it relates to clients or customers who instruct their credit card issuer to cancel payment to us without having first provided an acceptable reason to us and given us the opportunity to refund their money.

13. Data that may be processed outside the European Union

Our websites are hosted in the UK.

We do not currently use any non-UK or non-EU outsourced data processing services where data obtained in the UK may be processed.

Access to your own information

14. Access to your personal information

1. 1. At any time you may review or update personally identifiable information that we hold about you, by sending a request titled “Subject access request” to [insert email address]
   2. After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.

15. Removal of your information

If you wish us to remove personally identifiable information from our systems, you may contact us at [insert email address]

This may limit the service we can provide to you.

16. Verification of your information

When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

Other matters

17. Use of site by children

1. 1. We do not sell products or provide services for purchase by children, nor do we market to children.
   2. If you are under 18, you may use our website only with consent from a parent or guardian

18. How you can complain

1. 1. If you are not happy with our privacy policy or if you have any complaint then you should tell us by email. Our address is [insert email address].
   2. If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
   3. If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office. This can be done athttps://ico.org.uk/concerns/

19. Retention period for personal data

Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:

1. to provide you with the services you have requested;
2. to comply with other law, including for the period demanded by our tax authorities;
3. to support a claim or defence in court.

20. Compliance with the law

Our privacy policy has been compiled so as to comply with the law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we should like to hear from you.

However, ultimately it is your choice as to whether you wish to use our website.

21. Review of this privacy policy

We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.

If you have any question regarding our privacy policy, please contact us.