Privacy Notice
Introduction
The Tufton Group respects your privacy and is committed to keeping your personal data safe and secure. This Privacy Notice explains how we collect and process your personal data and how we apply the data protection principles. We keep our privacy notice under review to ensure that it is accurate and up to date and we will place any updates on our webpage www.tufton.com. It is important that you notify us of any changes to your personal information so that we can ensure that the information we hold on you is accurate and up to date.
The UK General Data Protection Regulation (UK GDPR) or its equivalents, the EU GDPR and the IOM Applied GDPR apply to Tufton Group companies. Personal data is information that relates to an identified or identifiable individual and it is possible to identify an individual directly or indirectly from the information.
Data Controller
Tufton Investment Management Ltd is the Data Controller responsible for the processing of any of your personal data that you share with us. We will process your personal data in a lawful, fair and transparent manner.
Types of personal data we collect
We collect and process the following personal data from you:
• Personal Identification information (Name, email address, phone number, residential address, date and place of birth)
• Photographic identification
• Source of Wealth and/or Source of Funds information
We collect and process the following personal about you from other sources:
• Sanctions and PEP status
We only process criminal offense data to the extent permitted and required by law.
How we collect your personal data and why we have it
We collect most of the personal data that we process directly from you for the following purposes:
• To provide our services to you
• To perform a contract with you
• To comply with regulatory and legal requirements
• For our own and your legitimate interests (when it is for our own legitimate interests, we will only process your data when your fundamental rights to privacy do not override our interests)
• For a specific purpose to which you have consented to (and to which you can withdraw your consent at any time).
We may also receive your information indirectly from the following sources for the purposes set out below:
• LSEG World-Check for sanctions and PEP status from time to time
• Internet searches to verify your personal information
We require this information as part of our legal obligation and contractual requirement. Failing to provide the personal data that we require under a legal obligation or to perform the contract we have with in relation to providing services to you may mean that we have to suspend or stop some or all of the services that we provide to you.
Automatic decision making, profiling and marketing
We do not use automated decision-making systems, or any profiling to process your personal information and we will not share your personal information for marketing purposes.
Our lawful basis for processing your personal information
The lawful basis that we rely on for processing your personal information are:
• Contractual obligation (to fulfil our contractual obligations with you)
• Legal obligation (to fulfil our legal and regulatory obligations)
• We have a legitimate interest
• For your own legitimate interest
Transferring and sharing your personal information
The personal information that we collect may be shared with other members of the Tufton Group in the UK, Isle of Man and Cyprus. Each of these countries has equivalent standards of data protection requirements. We may share your personal data with other professional service providers to conduct identification and monitoring checks. We will not share your information with anyone else unless we are required to do so by law.
If we are required to transfer your personal data outside of the EEA we ensure that a similar degree of protection is afforded to it.
How we store and protect your personal information
Your personal information is securely stored and processed in the UK. We have a comprehensive set of internal policies, procedures and processes in place to ensure that your personal data is stored and processed securely at all times.
If we transfer your information to another member of the Tufton Group it will be stored and processed at that office location in either the Isle of Man, Cyprus or the UK. We ensure that any third parties that we deal with keep all information they process on our behalf secure to the same standards that we do.
We will only store your personal data for as long as it is needed for the purposes that it was collected for or for as long as the law requires us to keep it. We will then dispose of your personal information securely by ensuring permanent deletion or destruction. We keep your personal data for a period of 7 years following the end of our relationship unless we are required to keep it for longer under law. Any data we process under your consent is deleted immediately on withdrawal of your consent.
Other privacy information
Our online Privacy Policy explains how we collect and process your personal data when you visit our website.
Your data protection rights
Under data protection law you have a number of rights. Please refer to our ‘Your Data Protection Rights’ document for further information on your rights, how they can apply and how you can exercise them.
How to contact us or make a complaint
If you have any questions, concerns or complaints about our privacy policy, the data we hold on you, how we are using your data or you would like to exercise one of your data protection rights, please do not hesitate to contact us.
Email us at: anthony.haynes@tufton.com
Call us: +44 (0)20 7518 6700
Or write to us at:
Representative in the UK
Tufton Investment Management Ltd
70 Pall Mall
London
SW1Y 5ES
United Kingdom
Representative in the EU
Tufton Asset Management Limited
142 Franklin Roosevelt
Limassol
CY-3011
Cyprus
You can also complain with a supervisory authority. Should you wish to report a complaint or if you feel that Tufton has not addressed your concern in a satisfactory manner, you may contact the Information Commissioner’s Office.
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk