Privacy

Square Mile Investment Consulting and Research Limited and Square Mile Investment Services Limited ("Square Mile", "we", "us" or "our") are committed to protecting the privacy of individuals whose data it processes ("you" or "your").

Structure of this policy

1. IMPORTANT INFORMATION AND WHO WE ARE

2. CATEGORIES OF DATA SUBJECTS

(A) CLIENTS

(B) JOB APPLICANTS

(C) VISITORS TO OUR WEBSITE

(D) BUSINESS CONTACTS

3. DISCLOSURES OF YOUR PERSONAL DATA

4. INTERNATIONAL TRANSFERS

5. DATA SECURITY

6. YOUR LEGAL RIGHTS

7. FURTHER INFORMATION

1. IMPORTANT INFORMATION AND WHO WE ARE

Square Mile Investment Consulting and Research Limited and Square Mile Investment Services Limited ("Square Mile", "we", "us" or "our") are committed to protecting the privacy of individuals whose data it processes ("you" or "your") on its own behalf as a controller and/or as a processor in respect of services it provides to certain clients.

This privacy policy aims to give you information on how Square Mile collects and processes your personal data (a) as a controller through your use of this website, by signing up to our newsletters, by applying for employment and/or to work with Square Mile, by sending us correspondence and/or providing us with products and/or services; and (b) a processor in respect of services it provides to clients.

In addition, it outlines your data protection rights under the EU data protection regime introduced by the General Data Protection Regulation (Regulation 2016/679) (the “GDPR"). This website is not intended for children and we do not knowingly collect data relating to children.

Please contact Square Mile Investment Consulting and Research Limited (registered number 08791142)/Square Mile Investment Services Limited (registered number 08743370), both of 15 Old Bailey, London, EC4M 7EF if you have any queries in relation to the processing of your personal data under this policy.

The Director of Operations is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Director of Operations at 15 Old Bailey, London, EC4M 7EF.

Square Mile may from time to time update this policy. Please refer back to this page regularly to see any changes or updates to this policy.

2. CATEGORIES OF DATA SUBJECTS

(A) CLIENTS

The following section of this policy sets out how Square Mile, as processor of data from its clients, will process such personal data (acting as controllers (or, in limited situations, as processor).

We may hold personal data about clients which is provided to us by you directly as a result of your relationship with Square Mile (i.e. through our website, telephone calls and/or corresponding with us) or which is provided to us by third parties. If you provide Square Mile with personal data relating to another data subject, you agree to provide that data subject with a copy of Square Mile's privacy policy.

In connection with providing the services, we may collect, store, and use the following categories of personal information: contact details (including name, title, address, telephone number, personal email address), your date of birth, copies of passport, driving licences and utility bills, national insurance number, bank account details and details relating to your investment activity.

Your personal data may be processed by Square Mile or its sub-processors (or any of their affiliates, agents, employees, delegates or sub-contractors) for the following purposes:

(a) to provide you with information about the services, which is being carried out to pursue Square Mile and/or the Funds' legitimate interests and/or to comply with applicable law;

(b) to update and maintain records which is necessary to comply with Square Mile's legal obligations;

(c) to carry out anti-money laundering checks and other actions in an attempt to detect, prevent, investigate and prosecute fraud and crime, which Square Mile considers necessary for compliance with Square Mile's legal obligations, for the performance of a task being carried out in the public interest and/ or to pursue Square Mile's legitimate interests (including for the prevention of fraud, money laundering, sanctions, terrorist financing, bribery, corruption and tax evasion);

(d) to prepare tax related information in order to report to tax authorities in compliance with a legal obligation to which Square Mile is subject; and

(e) to scan and monitor emails sent to us (including attachments) for viruses or malicious software, to process and encrypt personal data to protect and manage email traffic, and to store personal data on our systems to pursue Square Mile's legitimate interests including for document retention purposes; and

(f) such other actions as are necessary to manage the activities and/or to comply with the legal obligations of Square Mile, including by processing instructions, monitoring and recording electronic communications (including telephone calls and emails) for quality control, analysis and training purposes and enforcing or defending the rights and/or interests of Square Mile, in order to comply with Square Mile's legal obligations and/or to pursue Square Mile and/or the Funds' legitimate interests.

Where such processing is being carried out on the basis that it is necessary to pursue Square Mile's legitimate interests, such legitimate interests are not overridden by your interests, fundamental rights or freedoms. Such processing may include the use of your personal data for the purposes of sending you electronic marketing communication, in relation to which you can at any time unsubscribe by following the instructions contained in each marketing communication.

Square Mile does not anticipate being required to obtain your consent for the processing of your personal data as listed above. If Square Mile wish to use your personal data for other purposes which do require your consent, Square Mile will contact you to request this.

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us at 15 Old Bailey, London, EC4M 7EF.

(B) JOB APPLICANTS

The following section of this policy sets out how Square Mile may process personal data (as a controller) about applicants of jobs or placements and potential workers and contractors. Square Mile is the data controller of the personal data that you provide or which is provided to or collected by Square Mile during and/or in connection with any application for a position at Square Mile.

In connection with your application for work with us, we will collect, store, and use the following categories of personal data about you: name, title, address, telephone number, personal email address, date of birth, gender, employment history, qualifications, copies of passport/driving licence, contact details, bank account details, national insurance number, family member details, appraisals, information provided during telephone calls, interviews and/or meetings with you, information contained in your CV and cover letter or email, information obtained from social media, including LinkedIn, references and other information generated in the course of employment, details of salary, bonuses and other emoluments paid and of taxes deducted from those, information obtained from monitoring activities such as email monitoring and CCTV.

We may also collect, store and use the following "special categories" of sensitive personal data: Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions, information about your health, including any medical condition, health and sickness records and/or information about criminal convictions and offences.

We may collect personal data about candidates from the following sources: you, the candidate directly; recruitment agencies; background check providers; credit reference agencies; disclosure and barring service in respect of criminal convictions; your named referees; and data from third parties from a publicly accessible source including Companies House records and social media (such as LinkedIn).

Your personal data may be processed by Square Mile or its sub-processors (or any of their affiliates, agents, employees, delegates or sub-contractors) for the following purposes:

• to assess your skills and qualifications, to consider your suitability for the position and to decide whether to enter into a contract with you;

• to carry out background and reference checks, where applicable;

• to communicate with you about the recruitment process;

• to keep records related to our hiring processes;

• to comply with legal or regulatory requirements;

• to scan and monitor emails sent to us (including attachments) for viruses or malicious software, to process and encrypt personal data to protect and manage email traffic, and to store personal data on our systems to pursue our legitimate interests including for document retention purposes; and

• such other actions as are necessary to manage the activities of the Square Mile, including by processing instructions, monitoring and recording electronic communications (including telephone calls and emails) for quality control, analysis and training purposes and enforcing or defending the rights and interests of Square Mile, in order to comply with its legal obligations and/or to pursue its legitimate interests.

We process this personal data on the basis of our legitimate interests (in order to decide whether to appoint you to work for us) and/or in order to comply with applicable laws. Once we receive your CV and covering letter or your application form, we may process that information to decide whether Square Mile has any suitable vacancies and if you meet the basic requirements to be shortlisted for that role. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the work.

Your information will be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.

The Company will not share your data with third parties, unless your application for employment is successful and it makes you an offer of employment. The Company will then share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks and the Disclosure and Barring Service to obtain necessary criminal records checks and IT service providers.

If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.

We will use your sensitive personal data in the following ways:

• we will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during the interview; and

• we will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure equal opportunity monitoring and reporting.

• We envisage that we will process information about criminal convictions. We will collect information about your criminal convictions history if we would like to offer you the work or a position (conditional on checks and any other conditions, such as references, being satisfactory). We are entitled to carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role. In particular:

• We are legally required by the UK Financial Conduct Authority to carry out due and diligent enquiry into persons carrying out any FCA controlled functions.

We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.

If your application is successful, the information you provide during the application process will be retained by Square Mile as part of your employee file and held in accordance with Square Mile's employee privacy policy and data retention policy or applicable laws.

If your application is unsuccessful, the information you have provided will be retained by Square Mile for six (6) months after we have communicated to you our decision to you. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with our data retention policy or applicable laws and regulations. If we wish to retain your personal information on file, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis.

As a data subject, you have a number of rights. You can:

• access and obtain a copy of your data on request;

• require the Company to change incorrect or incomplete data;

• require the Company to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing; and

• object to the processing of your data where the Company is relying on its legitimate interests as the legal ground for processing.

If you would like to exercise any of these rights, please contact the Director of Operations at 15 Old Bailey, London, EC4M 7EF.

If you believe that the Company has not complied with your data protection rights, you can complain to the Information Commissioner. Contact details can be found on the website: www.ico.org.uk.

(C) VISITORS TO OUR WEBSITE

The following section of this policy sets out how Square Mile may process personal data (as a controller) about visitors to its website.

We may collect, use, store and transfer different kinds of personal data about you which you provide to us though our website: name, date of birth, address, email address, telephone numbers, technical data (including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website, usage data (including information about how you use our website, products and services, and marketing and communications preferences (including your preferences in receiving marketing from us and your communication preferences).

We do not collect any sensitive personal data or special categories of personal data about you through our website (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences through our website.

We use different methods to collect data from and about you including through:

• direct interactions with you, including by filling in forms. This includes personal data you provide when you subscribe to our publications and/or request marketing to be sent to you.

• Automated technologies or interactions. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies.

• Technical data from the following parties:

(a) analytics providers such as Google based outside the EU;

We will use your personal data in the following circumstances: where it is necessary for our legitimate interests, or those of a third party (including in relation to the sending of electronic marketing communications) and where your interests and fundamental rights are not overridden by those interests, or where we need to comply with a legal or regulatory obligation. Your personal data may be processed by Square Mile or its sub-processors (or any of their affiliates, agents, employees, delegates or sub-contractors) for the following purposes:

• to send you updates on the services we provide, newsletters, invitations to events and other electronic marketing communications which we will do (a) on the basis of our legitimate interests if you are a client or if we are sending electronic marketing communications to corporate subscriber email addresses (eg name@company.com) or (b) with your consent;

• to use data analytics to improve our website, marketing, customer experiences on the basis of our legitimate interests;

• to comply with legal or regulatory requirements;

• to scan and monitor emails sent to us (including attachments) for viruses or malicious software, to process and encrypt personal data to protect and manage email traffic, and to store personal data on our systems to pursue our legitimate interests including for document retention purposes; and

• such other actions as are necessary to manage the activities of Square Mile, including by processing instructions, monitoring and recording electronic communications (including telephone calls and emails) for quality control, analysis and training purposes and enforcing or defending the rights and/or interests of Square Mile, in order to comply with their legal obligations and/or to pursue their legitimate interests.

If we consider it necessary to obtain your consent in relation to the use of your personal data, we will contact you to request this consent. In such circumstances, we will provide you with full details of the personal data that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. If you decide to provide your consent, you have the right to withdraw your consent at any time, although that will not affect the lawfulness of processes based on consent before its withdrawal. To withdraw your consent or to opt out of receiving marketing communication, please contact us at 15 Old Bailey, London, EC4M 7EF or following the unsubscribe instructions included in each electronic marketing communication. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us at 15 Old Bailey, London, EC4M 7EF.

Where our website provides links to other websites, Square Mile is not responsible for the data protection/privacy/cookie usage policies of such other websites, and you should check these policies on such other websites if you have any concerns about them. If you use one of these links to leave our website, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting a linked website and such websites are not governed by this policy. You should always exercise caution and review the privacy policy applicable to the website in question.

Cookies: A cookie is a small file which asks permission to be placed on your computer. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular website. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

Overall, cookies help us provide a better website by enabling us to monitor which pages users find useful and which they don’t. A cookie does not give us access to a user’s computer or any information about them, other than the data they choose to share with us.

The browsers of most computers, smartphones and other web–enabled devices are usually set up to accept cookies. If your browser preferences allow it, you can configure your browser to accept all cookies, reject all cookies, or notify you when cookies are set. Each browser is different, so check the “Help” menu of your browser to learn about how to change your cookie preferences.

However, please remember that cookies are often used to enable and improve certain functions on our website. If you choose to switch certain cookies off, it will affect how our website works and you may not be able to access all or parts of our website.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

You can find more information about the individual cookies that we use and the purposes for which we use them below:

Third Party Cookies

To support our services, we sometimes embed photos and video content from websites such as Wistia, YouTube and Flickr. As a result, when you visit a page with content embedded from, for example, Wistia, YouTube or Flickr, you may be presented with cookies from these websites. Square Mile does not control the dissemination of these cookies. You should check the third party websites for more information about these.

Google Analytics

Square Mile uses Google Analytics, a web analytics service provided by Google, Inc. Google Analytics sets a cookie in order to evaluate your use of website(s) and compile reports for us on website activity.

Google stores the information collected by the cookie on servers in the United States. 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 will not associate your IP address with any other data held by Google.

By using our website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

For more information on the cookie set by Google Analytics, including information on how to opt out please go to: http://www.google.com/intl/en/privacypolicy.html

Cookies List

Logged out.

1. .ASPXANONYMOUS – Mon 2nd July 2018 (47 days)

This cookie stores a session ID for users who have not registered and logged in to the website to view standard website content.

2. _atuvc – Sat 25th May 2019 (374 days)

_atuvc is a cookie that enables the sharing of content over a range of platforms via the AddThis social widget. This cookie identifies the types of devices used only.

3. _Request Verification Token – Session

This cookie is generated by ASP.NET MVC and is designed to protect our website against malicious form post attacks.

4. _utma – Fri 15th May 2020 (2 years)

This cookie keeps track of the number of times a visitor has been to the site according to the cookie, when their first visit was, and when their last visit occurred. Google Analytics uses the information from this cookie to calculate statistics such as visits per day.

5. _utmb – Wed 16th May 2018 (1 day)

The B and C cookies work together to calculate how long a visit takes. __utmb takes a timestamp of the exact moment in time when a visitor enters a site, while __utmc takes a timestamp of the exact moment in time when a visitor leaves a site. __utmb expires at the end of the session. __utmc waits 30 minutes, and then it expires.

6. _utmc – Session

See above.

7. ~_utmz – Wed 14th November 2018 (182 days)

__utmz keeps track of where the visitor came from, what search engine they used, what link they clicked on, what keyword they used, and where they were in the world when they accessed a website. It expires in 15,768,000 seconds – or, in 6 months. This cookie is how Google Analytics knows to whom and to what source / medium / keyword to assign the credit for a Goal Conversion.

8. _ga – Thu 16th May 2018 (1 day)

This cookie is used by Google Analytics to distinguish users, it has an expiration time of 2 years

9. ASP.Net SessionId – Session

This cookie is set by ASP.NET and stores the identifier of the current user's session i.e. Every time a user visits the website, they have a unique session ID. This stops page requests from being seen as independent requests, but part of a string of requests. This lasts for the user's current session only. A session is defined as the period of time that a unique user interacts with a Web application.

10. CookieDirective – Mon 23rd July 2018 (68 days)

This cookie is used to identify when the cookie directive warning should be displayed to a new visitor when they enter the website. It will continue to show until the user accepts the notice.

11. Dnn_IsMobile – Session 

This cookie detects mobile devices and if one exists will direct users to a mobile version of the website.

12. euCookieLaw – Sun 23rd April 2028 (10 years)

This cookie is used to identify when the cookie directive warning should be displayed to a new visitor when they enter the website. It will continue to show until the user accepts the notice.

13. language – Session

Stores user location to deliver country specific content.

Logged in (as well as the cookies above you also have…)

1. .DotNetNuke - Session

This is a cookie that is set by Forms Authentication mode, which authenticates the user and keeps them logged in.

2. LastPageID - Session

This cookie identifies the last page that was visited.

3. StayInEditMode - Session

This is a functional administration cookie that really only affects logged in users and administrators of the website, ensuring that the correct mode "edit mode" is the default setting for making website changes.

For further details on cookies (including how to turn them off) can be found at www.allaboutcookies.org.

(D) BUSINESS CONTACTS

The following section of this policy sets out how Square Mile may process personal data (as a controller) about its business contacts and (current, previous and/or potential) service providers (and employees of service providers) and data subjects that have provided a business card to, or have corresponded with, an employee of Square Mile.

We may collect, use, store and transfer different kinds of personal data about you which you provide to us including: name, date of birth, address, email address, telephone numbers, place of work and job title.

We will use your personal data in the following circumstances: where it is necessary for our legitimate interests, or those of a third party (including in relation to the sending of electronic marketing communications) and where your interests and fundamental rights are not overridden or where we need to comply with a legal or regulatory obligation.

Your personal data may be processed by Square Mile or its sub-processors (or any of their affiliates, agents, employees, delegates or sub-contractors) for the following purposes:

• to hold your personal data on our system and to contact you on the basis of the legitimate interests of Square Mile (including in connection with using the services that you provide);

• in respect of suppliers, to allow us to process payments and orders in respect of any goods and services provided;

• to send you updates on the services we provide, newsletters, invitations to events and other electronic marketing communications which we will do (a) on the basis of our legitimate interests if you are a client or if we are sending electronic marketing communications to corporate subscriber email addresses (eg name@company.com) or (b) with your consent;

• to comply with legal or regulatory requirements;

• to scan and monitor emails sent to us (including attachments) for viruses or malicious software, to process and encrypt personal data to protect and manage email traffic, and to store personal data on our systems to pursue our legitimate interests including for document retention purposes; and

• such other actions as are necessary to manage the activities of Square Mile, including by processing instructions, monitoring and recording electronic communications (including telephone calls and emails) for quality control, analysis and training purposes and enforcing or defending the rights or interests of Square Mile, in order to comply with their legal obligations and/or to pursue their legitimate interests.

If we consider it necessary to obtain your consent in relation to the use of your personal data, we will contact you to request this consent. In such circumstances, we will provide you with full details of the personal data that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. If you decide to provide your consent, you have the right to withdraw your consent at any time, although that will not affect the lawfulness of processes based on consent before its withdrawal. To withdraw your consent or to opt out of receiving marketing communication, please contact us at 15 Old Bailey, London, EC4M 7EF or following the unsubscribe instructions included in each electronic marketing communication. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Where such processing is being carried out on the basis that it is necessary to pursue Square Mile's legitimate interests, such legitimate interests do not override your interests, fundamental rights or freedoms. Such processing may include the use of your personal data for the purposes of sending you electronic marketing communication, in relation to which you can at any time subscribe by following the instructions contained in each marketing communication.

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us at 15 Old Bailey, London, EC4M 7EF.

3. DISCLOSURES OF YOUR PERSONAL DATA

We will not disclose personal information we hold about you to any third party except as set out below.

We may disclose your personal data to other members of our group, to third parties who are providing services to us including IT service providers, event management, PR and marketing service providers, analytics and search engine providers that assist us in the improvement and optimisation of the website, background and/or credit reference services, processors (including printers, registrars, administrators) telephone service providers, document storage providers, backup and disaster recovery service providers.

We may also disclose personal data we hold to third parties:

(a) in the event that we sell any business or assets, in which case we may disclose personal data we hold about you to the prospective and actual buyer of such business or assets; and/or

(b) if we are permitted by law to disclose your personal data to that third party or are under a legal obligation to disclose your personal data to that third party.

4. INTERNATIONAL TRANSFERS

We do not transfer your personal data outside the European Economic Area (EEA) directly ourselves. However, some of the external services providers used by our external services provides are based outside the European Economic Area (EEA) so their processing of your personal data may involve a transfer of data outside the EEA. Whenever your personal data is sent out of the EEA by us, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used when transferring your personal data out of the EEA.

5. DATA SECURITY

Square Mile has put in place measures to ensure the security of the personal data it collects and stores about you. It will use its reasonable endeavours to protect your personal data from unauthorised disclosure and/or access, including through the use of network and database security measures, but it cannot guarantee the security of any data it collects and stores.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

6. YOUR LEGAL RIGHTS

In certain circumstances, by law you have the right to:

• Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

• Request the transfer of your personal information to another party.

• Withdraw your consent. If we are processing your personal data on the basis of your consent, you have the right to withdraw such consent at any time. Withdrawing your consent will not affect the lawfulness of processes based on consent before its withdrawal. To withdraw your consent or to opt out of receiving marketing communication, please contact us at 15 Old Bailey, London, EC4M 7EF or following the unsubscribe instructions included in each electronic marketing communication. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. If you wish to exercise any of the rights set out above, please contact the Director of Operations, 15 Old Bailey, London, EC4M 7EF in writing.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

7. FURTHER INFORMATION

If you have any queries about this policy or your personal data, or you wish to submit an access request or raise a complaint about the way your personal data has been handled, please do so in writing and address this to the Director of Operations at Square Mile, 15 Old Bailey
London, EC4M 7EF or by email to info@squaremileresearch.com.

Square Mile Investment Consulting and Research Limited is a private limited company registered in England and Wales (registered number 08791142) having its registered office at 130 Wood Street, London, EC2V 6DL and principal place of business at 15 Old Bailey, London, EC4M 7EF.

Square Mile Investment Services Limited is a private limited company registered in England and Wales (registered number 08743370), having its registered office at 130 Wood Street, London, EC2V 6DL and principal place of business at 15 Old Bailey, London, EC4M 7EF. Square Mile Investment Services Limited is authorised and regulated by the Financial Conduct Authority.

Data Protection and Privacy Policy

Last Updated May 2018

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