If you wish to amend any of the personal information that we hold about you, you can do so at any time by contacting us.
If you have any queries about how we use your personal information, please contact our Managing Director (firstname.lastname@example.org).
Information we collect
This section details the information we may collect about you. We explain why, and how, we use it in later sections.
If you decide to register to become a Member, we may ask you to provide us with some specific information, for example:
- Basic personal details (e.g. Full Name)
- Work contact details (e.g. email, telephone number)
- Employment details (e.g. job title, company name)
- Log in details
Information we obtain through cookies and similar tools
Lawful basis for processing
We only process personal information where we have a lawful basis for doing so, such as the following:
- User consent
- Legitimate business purposes
- Contractual necessity
- Legal obligation
How we use your information
We collect information for nine main reasons:
- To provide our service – We require some of your basic personal information so our services work as you would expect, for example, delivering notifications of new Content to your correct email address or providing CPD certification
- To improve and maintain performance
- To monitor compliance with our User Agreement, policies and terms
- To personalise our products and services – We improve your experience of our products and services by personalising parts of our Websites with the information you give us and what we learn about you. This includes showing you Content you may be interested
- To communicate product changes and offers
- To pass on to our Partners when you view their Content
Who we share your personal information with
Where relevant and applicable, we will disclose your information to certain third parties. Commonly, we will disclose information to:
- Advertisers and sponsors – We share aggregated, non-identifiable information with third parties. Before sharing this information, we ensure that it cannot identify you as an individual. For example, we may release information about the size and growth of our digital audience
How long we retain your personal information
We retain the majority of your personal information for as long as your membership is active and therefore open; this allows you to continue accessing our content, products and services.
If you become inactive, we may delete elements of the information associated with your account. We will normally warn you if your access is going to be withdrawn and give you the opportunity to retain your account.
Where we don’t need to keep all of your information in full, we will obfuscate or aggregate it, for example, web activity logs and survey responses. This is to ensure that we do not retain your information for any longer than is necessary.
It is sometimes necessary for us to keep your information for longer periods of time, for example: If there is a statutory requirement to retain it; If we require the information for legal reasons or there is a legitimate business need for us to retain it; To ensure we do not contact you if you have asked us not to.
How we keep your personal information secure
We have endeavoured to put appropriate technical and administrative security measures in place to help ensure that our users’ information is protected against unauthorised or accidental access, use, alteration, or loss.
Under data protection laws, you have rights as an individual in relation to any personal data we hold about you. You can exercise these rights through your account or by contacting our Managing Director (email@example.com). You also have the right to lodge a complaint with a supervisory authority. In the UK, this is the Information Commissioner’s Office (ICO).
Our Websites are not intended for children under 16 years of age. We do not intentionally collect or use any information from children. The Website is designed only for use by Professional Investors with discretionary investment authority or influence. If you are not a professional person working in investment management or in an investment research or investment support role, you must not register or gain access to the Website and its Content. The Content of this Website is similarly designed only for use by Professional Investors who are based in Europe, including the United Kingdom, the Channel Islands, European Union and European Economic Area countries, and Switzerland. If you are not based and authorised to practise in Europe, you must not register or try to gain access to the Website and its Content. You represent and warrant that you are 18 years of age or older and are fully able and competent to enter into, and abide by, this policy.
If you have a query in regards to the processing of your information, please contact our Managing Director (firstname.lastname@example.org).
ETF Strategy Limited
8 Denmark Street
London WC2H 8LS
This policy is effective from 10th December 2021.