TAM Asset Management Limited, is registered in England under number 4077709, registered office 10th Floor, City Tower, 40 Basinghall Street, London EC2V 5DE. TAM Asset Management Limited is authorised and regulated by the Financial Conduct Authority (FCA), FRN: 208423.
TAM Asset Management Limited and its affiliates (“TAM”) are fully committed to safeguarding your privacy, whether online or otherwise, and the success of our business depends upon our ability to maintain the trust of our clients. Protecting the confidentiality of your personal information is of paramount importance to us here at TAM and we appreciate any concerns you may have about the privacy of personal information that you provide to us - whether through your Independent Financial Adviser (IFA), our website or in other ways. This is critical not only for the maintenance of our reputation but also to satisfy the legal and regulatory requirements of the EU General Data Protection Regulation (EU GDPR) imposed on us to safeguard our clients and maintain orderly markets.
Where we refer to “personal information” or “personal data” in this Policy, we mean information which identifies you as an individual, or is capable of doing so. In the context of this Policy, the terms “personal information” and “personal data” may be used interchangeably. We may hold and use data about you in the capacity as a consumer, business customer, individual, as a shareholder, or any other capacity in which you may visit our websites.
This Policy applies to information that we hold about you and aims to provide a summary of the type of information we collect and how this information is used.
When you become a client of TAM, we will ask you to provide us with certain information including personal data. There are two types of information that we collect from our clients, namely:
- Personal information which includes but is not limited to our client’s name, residential address, date of birth, e-mail address, employment details and information relating to your financial circumstances;
- Information relating to the visitors when visiting our website.
We may supplement the information that you provide us with information that we receive from our Service Providers and or other third parties such as your IFA or Intermediary. This information will enable us to provide you with a professional service and help us to keep you informed with research and other information that you may be interested in.
How we acquire your information
Most of the information that TAM receives will comes directly from you or your Financial Adviser or Intermediary, normally at the point when you register, apply to use any of our services, become a client or, complete a contact form on our website. We may also obtain personal information about you from other sources, such as:
- Fraud prevention agencies;
- Identification verification checks;
- Tracing companies, should we lose contact with you so as to keep you updated with regards your investments;
- Web search – we may search for your contact details over the web.
- Platforms – where our services are distributed through a platform, the platform may forward us a breakdown of the investments, including the name of your IFA;
- Risk and Compliance portals to conduct regulatory checks;
- Third party cookies where we collect information on how visitors use our website;
- We also record all calls in order to comply with our regulatory obligations.
The types of personal data we might collect and process
We may collect and process the following data:
- Information about you such as name, title, date of birth, gender, nationality, country of birth, country of residence, employment status, email address, post code, contact number. We require this information not only to help us to identify you, but also to allow us to contact you;
- Government Identification documentation such as Passport details, Driving Licence, National Insurance Number, Tax Identification Number and utility bills;
- Government Records that may be held by financial crime prevention agencies, the Electoral Register and by Utility Services providers;
- Financial Information such as bank account details for payments made to TAM or payments TAM make to you;
- Income/Wealth such as your employment status, income and source of wealth;
- Contractual Information such as details regarding your products and benefits that we may provide;
- Third Party information, where relevant such as your IFA , Intermediary, Executor, or any Power of Attorney etc.;
- Online Information such as – cookies and IP address, if you use our website
- Audio Recordings such as voice recording if you, or your IFA or Intermediary, contact us. These are recorded for regulatory purposes.
Full details of the purposes for collecting Personal Data are set out in our Data Protection registration with the ICO under Registration Number: ZA074223. https://ico.org.uk/ESDWebPages/Entry/ZA074223
Why we collect, use, share and store information about you
We collect, use, share and store information about you to provide you with the services that you have requested from us and share information with you about the services that we offer that may be of interest to you. We will collect information directly from you or from third parties such as your IFA.
In some case, you are not obliged to provide any personal data to us but if you have requested information or a service or product from us, we will not be able to provide it without certain information. Before providing you with our services, we are required to obtain certain information about you so as to verify your identity and meet our obligations under The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 along with any other applicable legislation and for the purposes of crime and/or fraud prevention. Unless otherwise stated, the legal basis for our use of your personal data will be that this information is required for one or more of the legitimate interests as described in this Policy.
How we use your personal Data:
We use any information obtained directly from you or your IFA or Intermediary for a number of reasons. This will depend on which category you fit into and the processing carried out by us directly or trusted third party companies that we use.
We use information in the following ways:
- to provide our services to you;
- Processing your investment application;
- Where we have an obligation to do so, such as identification verification with fraud prevention agencies to enable us to comply with our anti-money laundering obligations and for the purposes of crime and fraud prevention and to protect our business interests;
- To help protect your information and prevent unauthorised access to it;
- To comply with our obligations arising from any agreements entered into between you, your IFA and TAM;
- Carry out regulatory checks and meet any legal or regulatory obligations;
- Producing tax reports such as a Consolidated Tax Voucher, CGT Report etc.,
- Completing any enquiry or requests you may make;
- Keeping you updated with regular/quarterly reports;
- Sending you marketing emails to keep you informed about products and services you hold with us (including those of other companies within the TAM Group) that may be of interest to you. (You may opt out of receiving this information when we collect your details or at any time by contacting the Head of Legal & Compliance at the address below);
- Maintaining a backup of our investment register for Business Continuity purposes;
- Where we have an obligation in law and to the extent necessary for the proper operation of our systems
- To notify you of any changes to our services, and
- To help improve the services that we provide to you.
Who we share your data with
We will endeavour to maintain such information in accordance with our internal policies governing the use and disclosure of confidential information and will only use it for the stated purpose. We will not share this information with any third party outside TAM, other than with relevant Service Providers to enable them to assist in providing, maintaining and operating the Services, unless we have your prior permission to do so or are required to do so by law.
We may share your personal information with the following third parties:
- Your IFA or Intermediary where you have given your authority. Where transactions have been carried out through your IFA or Intermediary, that person will be deemed to be your agent to whom full details of your information under the Agreement may be disclosed unless you advise us to the contrary in writing;
- Our Service Providers and Agents (including their sub-contractors) and in order to provide and maintain the provision of the services, such as:
- Our custodian – (this is currently Pershing Securities Limited)
- IT companies who support our technology;
- Offsite storage firms;
- Confidential waste disposal;
- Printing firms
- Appointed Auditors, Accountants, Lawyers or other professional advisers to the extent that they require access to the information in order to advise us;
- HM Revenue & Customs;
- Regulators such as the Financial Conduct Authority (FCA), Information Commissioner (ICO) and other authorities as required;
- UK Financial Services Compensation Scheme (FSCS);
- Introducing firms;
- Market research agencies;
- Any third party as a result of any restructure, sale or acquisition of any company within the TAM Group, provided that any recipient uses your information for the same purposes as it was originally supplied to us and/or used by us;
- Anyone to whom we may transfer our rights and/or obligations under the Agreement;
- Any person notified by you as authorised to give instructions for the purposes of managing or administering the service provided under your Agreement with us, to the extent reasonably necessary to enable us to perform the services.
- Any person that you request us to share your information with;
- Businesses that are legally part of the TAM Group of Companies, or that become part of the Group;
- Where TAM has a duty to do so to meet applicable law and regulatory requirements, or if law or regulation allows us to do so.
TAM will not lend or sell your information to third parties, but we may provide access to your personal identifiable information when legally required to do so, to cooperate with police investigations or other legal proceedings, to protect against misuse or unauthorised use of our website, to limit our legal liability and protect our rights, or to protect the rights and safety of visitors to our website. In those instances, the information is provided only for that limited purpose.
International Transfers - Sharing your information outside the European Economic Area (EEA)
Subject to applicable law, TAM may share your personal information with our service providers and this may involve transferring it to countries outside the EEA whose data protections laws may not be as extensive as those to which this Policy applies. Where we share information with organisations in another jurisdiction, we will ensure that we do this in accordance with the Data Protection Laws and Regulations and take appropriate measures to ensure they agree to apply equivalent levels of protection. We will further ensure that we include conditions in the contract to protect all personal information to the standard required in the EEA. TAM may also share your information with other companies that are legally part of the TAM Group of companies for the purposes of providing our services to you. However, only the appropriate data controllers will have access to relevant investor data.
How we keep your personal data
TAM is committed to only keeping your personal information for as long as this is considered necessary, for the purposes for which it was collected, or as required by any laws that apply. This will include keeping your information for a reasonable period of time after your investment or relationship with us has ended. In the absence of specific legal, regulatory or contractual requirements, all other personal information is kept for seven (7) years after your investment has ended. In some cases, however, we are required to keep information for longer, such as the FCA requirement to retain pension transfer information indefinitely.
Accuracy of your personal information
We endeavour to ensure that the personal information we hold about you is accurate and up to date. Should the data we hold about you be inaccurate or outdate, we will correct it upon your request.
Changes to the way we use your personal data
Should there be any change in the way that we use your personal data, we will contact you to explain the reason for this and advise you as to why we are using your data and our legal reasons for the same.
Confidentiality & Security
TAM will endeavour to maintain confidential information in accordance with our internal policies governing the use and disclosure of confidential information and will only use it for the stated purpose. We take the protection of your personal data very seriously and take appropriate steps to ensure your personal data is stored in a secure environment to prevent any unauthorised access. We will not share this information with any third party outside TAM unless so required by law. For example, with authorities as the FCA or with any other regulatory authority to which we are subject or with any person empowered to require such information by or under any legal enactment.
Where TAM use external data service providers to process personal data on our behalf to enable them to assist in providing, maintaining and operating the Services required to fulfil our obligations to you, we will always ensure that we hold appropriate agreements in place to protect your data. Any data transfers between TAM and its external service providers are conducted by secure means. Where such service providers are located outside the EEA, TAM have additional contractual arrangements in place.
Protecting the Privacy and Safety of Children
TAM understands the importance of taking extra caution and consideration to protect the privacy and safety of children using our services. Therefore, any child under the age of thirteen years, or equivalent minimum age in relevant jurisdictions, shall not be permitted to use our services unless verifiable consent is given by their parents. Should it come to our notice that we have collected any information of any child under thirteen years, or equivalent minimum age in a relevant jurisdiction, without verifiable consent, we will ensure that we delete such information without undue delay.
If you are an account holder and/or an investor, business contact or newsletter subscriber covered by this Policy we will keep you updated with details of our (and of other companies within the TAM Group), products and services which we feel may be of interest to you. This would also include news and information about the financial markets and financial services. We will send such information by email using the contact details that you have provided to us. We will first obtain your permission if we use your personal email address or any other information required before sending any marketing information or communications. When you register with us or apply to use our services, you may specify your marketing and communication preferences or indicate that you do not wish to receive news or information from us. Should you consent to receiving marketing communications, you may change your preferences or opt out at a later date by contacting us, as set out below under ‘Contact Us’.
Further, we shall ensure that any third-party company that assist us in marketing our products and services, or with whom we have joint marketing agreements, are under contractual obligations to protect the confidentiality of your personal information and use it only to provide the services we have requested them to perform.
What are the legal grounds for using your data
Data Protection gives organisations such as TAM, a number of different conditions to allow it to process your Data lawfully and we will only use your personal information when one or more of these conditions has been satisfied.
What are your rights
Under certain circumstances, you have the following rights in relation to your personal information such as, the right to:
- access personal information about you and to obtain a copy of it;
- request rectification or completion of personal information which is inaccurate or incomplete;
- restrict the use of personal information such as processing your details for marketing purposes;
- object to the processing of your personal information;
- data portability - meaning, in certain specific circumstances, receive your personal information, which you have provided to us, in a structured, commonly used and machine-readable format and the right to transfer that information to another data controller without hindrance, or to have such personal information transferred to another data controller where technically feasible;
- request that the personal information is erased under certain circumstances;
- object to the processing of your personal information;
- be informed about any use of your personal information to make automated decisions about you, and to obtain meaningful information about the logic involved, as well as the significance and the envisaged consequences of the processing;
- prevent any processing of personal data that is causing or is likely to cause unwarranted and substantial damage or distress to you or another individual; and
- make a complaint to the ICO (the Information Commissioner’s Office) about the way in which your personal data is being used.
Should you wish to exercise any of these rights, please contact the Head of Legal & Compliance via our contact details below. Should you contact us to exercise any of the above rights, we may ask you to provide some additional information in order to verify your identity.
Reviews and updates to TAM’s Policies and Notices
TAM Asset Management Limited
40 Basinghall St
London EC2V 5DE
Date of Issue: 25th May 2018