Privacy Statement
Denver Capital is committed to maintaining your personal data in accordance with the requirements of our legal and regulatory data protection obligations and will take all reasonable steps to ensure that your personal data is kept secure.
Why we collect your data
We are committed to protecting your personal data. This statement explains how we do that. It sets out what we do with your personal data, how we protect it, and explains your pertinent privacy rights. We collect and use your personal data to enable us to conduct our business with you and to comply with the law. The basis we rely upon for lawfully collecting and using your personal data will depend on the purposes for which we are processing your personal data. These are detailed below:
(a) Performing our contract with you
When we do business with you, we do so under the Client Terms. For us to meet our obligations to you under the Client Terms we must process your personal data. We will only process your personal data in line with the Client Terms. When you provide personal data to us, we will use that personal data so we can:
- provide our services to you in the provision, administration and servicing of your account
- enable the conduct of security operations, such as using your IP address to help identify you when you log on to your account online
- identifying you when you contact us
- send you information about our products and services where appropriate
We will only process that data for the purposes for which it was collected or to meet our legal obligations.
(b) Our legitimate interests
We process your information for the following reasons, which we define as our legitimate interests:
- developing new services and products
- internal research and analysis
- to help us to run our business; this includes financial management, risk management, planning, corporate governance, audit and research
- marketing
- market research
(c) Our legal obligations
In some circumstances, we have a legal obligation to process and share your personal data. We must provide a wide range of data to regulators or other entities in order to prevent or detect crime. Sometimes this involves personal data. We will never transfer more personal data than is necessary to discharge our legal obligations.
(d) Your consent
We will ask you for your preferences in terms of how you would like us to communicate with you and what information you would like to receive from us. You can always adjust your communications preferences, and can opt not to receive information from us unless we are obliged to provide it.
What we collect and how
The personal data you provide to us will include combinations of any of the following: Your name, email address, telephone number, address, identification numbers such as National Insurance number, banking account details, date of birth, location information, employment information, gender, IP address, language, and marital status, dependants and beneficiaries and shareholders.
This information is typically provided to us by your adviser if you have one or by you through the course of your relationship with us. We hold your personal information relating to your account on paper and on computer systems.
Denver Capital may also need to hold and process sensitive information about you and/or your dependants and beneficiaries (known as “special category data”). Under legislation, details relating to health, racial or ethnic origin, religious or other similar beliefs, sexual orientation political affiliations and biometric data are regarded as “special category data”. Except where the legislation allows it, this information cannot be processed or passed to a third party without your explicit consent. If we need your consent to process or pass your special category data to a third party, we will ask you to provide it at the relevant time.
Who we share your personal data with
Like most businesses, we use third parties to help deliver our services. This will often involve a third party processing your personal data but that will only be in line with the purposes set out above. We operate a regular and strict regime of third party checks on how your personal data is protected.
Your personal data will be held in confidence by us but may be passed to other companies as detailed below:
- Denver Capital, their agents or any third parties we appoint for the administration and servicing of your account and carry out our legitimate interests, which may include the transfer of your information outside the UK and European Economic Area (EEA). Where we send the data of your dependants, beneficiaries or shareholders to such third parties you agree to inform and gain consent from the relevant persons.
- We, are provided with updated address details or other information by either you or your employer, in which case we will update the information kept for any other accounts for which we hold records on our database.
- If applicable to you, your adviser or intermediary - this would include any other party to the business relationship with your adviser or intermediary that you have told us about;
- HM Revenue & Customs, the Financial Conduct Authority and other statutory bodies (such as the Financial Ombudsman) – we can be fined and subject to other action if we fail to provide certain information to these authorities.
- Other organisations to help prevent and detect fraudulent behaviour and to authenticate customers using our online services.
- Fraud prevention and law enforcement agencies if false or inaccurate information is provided and fraud is identified. Denver Capital and other organisations may also access and use this information to prevent fraud and money laundering. If fraud is detected, you could be refused certain services, finance, or employment.
Please contact us if you wish to receive details of the relevant fraud prevention agencies, further details can be found regarding data protection rights and fraud prevention agencies at https://www.cifas.org.uk/fpn
- We and other organisations may access and use from other countries the information recorded by fraud prevention agencies.
- Our affiliated and associated companies for marketing purposes where you have provided your specific consent.
Any transfer of information will usually be by electronic means, including the internet.
Security of your personal data
Ensuring the confidentiality, integrity and availability of your personal data defines our approach to information security. We ensure that the security risks to your personal data are managed in a way that makes sure we meet our legal and regulatory obligations. We produce, maintain and regularly test our business continuity plans.
Marketing
We may collect and use your personal information for undertaking marketing by email, telephone and social media.
We may send you certain direct marketing communications by post if it is in our legitimate interests to do so for marketing and business development purposes. We will endeavour to send content that is relevant to you.
We will obtain your consent to direct marketing communications where we are required to do so by law. Where we rely on your consent to send direct marketing communications we will continue to do so.
You have the right to ask us not to process your personal information for marketing purposes. You can do this by using the unsubscribe link included in the emails we send you, or using the unsubscribe details provided on our direct mail. Please note that requests to unsubscribe via post may take longer than using the unsubscribe link in the footer of our emails.
Your rights
The law places robust obligations on entities in the protection of personal data. The way we protect your personal data reflects our legal obligations. A number of rights in relation to the use of your personal information empowers you to make certain requests of us, detailed as follows:
(a) Requesting a copy of your personal data
You can access the personal data we hold about you and exercise your right to have a copy provided to you, or someone else on your behalf, in a digital format by emailing or writing to us using the contact details set out in the Client Terms.
(b) Letting us know if your personal data is incorrect
If you think any of the personal data we hold about you is wrong please let us know by contacting us. We will check the accuracy of the information and take steps to correct it if necessary.
(c) Asking us to stop using or to erase your personal data
You have the right to object to our use of your personal data. You can ask us to delete it, to restrict its use, or to object to our use of your personal data for certain purposes such as marketing. If you would like us to stop using your data in any way, please get in touch. If we are still providing services to you we will need to continue using your information to deliver those services. In some circumstances we are obligated to keep processing your information for a set period of time.
Information will generally be provided to you free of charge, although we can charge a reasonable fee in certain circumstances.
How long do we keep your personal data?
We keep all personal data safe and only hold it for as long as necessary. To meet the requirements of UK tax law, we must keep your personal information for a minimum of 7 years.
How to complain
If you are unhappy with how we have used your personal data you can complain by contacting us, Denver Capital, 27 Old Gloucester Street, London, WC1N 3AX.
Finally, you also have the right to complain to your national data protection authority: Information Commissioner’s Office whose helpline number is: 0303 123 1113.
For visitors to the Denver Capital website arriving through a link from another site, Denver Capital is able to record through which link the site was visited. Please note that Denver Capital is not affiliated with, nor does it sponsor or endorse, any linking websites owned by third parties and it does not endorse any product or service offered by such linking sites.
We do not collect any personally identifiable data from you but, should you subsequently become a client, we will know the source through which you were introduced.
Unsubscribing from our email communications
You can unsubscribe from our emails at any time, there is a link at the bottom of all emails that are sent from us. Unsubscribing will mean that you won’t hear from us via email again until you change your contact preferences with us.