GDM Investment Holdings Limited (Company Number: 13086562) (“Company”, “we”, “us” or “our”) is committed to protecting the privacy and security of your personal data. This Privacy Notice describes how we collect, use and look after your personal data when you visit our website (regardless of where you visit it from) including when you submit a query through our ‘Contact Us’ page or use any other interactive services on our website which involve you submitting any of your personal data to us. It also tells you about your rights and how the law protects you.
This Privacy Notice is provided in a layered format so you can click through to the specific areas set out below. The Glossary sets out the meaning of terms used in this Privacy Notice.
Important information
The data we collect about you
How personal data is collected
How we use your personal data
Disclosure of personal data
International transfers
Data security
Data retention
Your legal rights
Schedule
- Important information
This policy is effective from 28/09/2018.
This Privacy Notice supplements the other notices on our website (including our terms of use (Terms)) and is not intended to override them.
GDM Investment Holdings Limited is the controller and responsible for your personal data.
To assist your understanding of this Privacy Notice, Schedule 1 contains a glossary of terms used in this Privacy Notice, examples of types of personal data we collect, how we use it, the lawful basis for processing such data and further details of your rights.
We have appointed a data privacy manager (DPM). If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact our DPM in writing, either:
by email to: marketing@gdmp.co.uk
by post to: FAO: The Data Privacy Manager, 99 Charterhouse Street, London EC1M 6HR
You have the right to make a complaint at any time to the ICO (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.
Our website is not intended for children and we do not knowingly collect data relating to children.
Your duty to inform us of changes
It is important that the data we hold about you is accurate and current, therefore please keep us informed of any changes to your personal data.
Third-party links
Our website may include links to third-party websites, plug-ins and applications. By clicking on these links or enabling connections you may be allowing third parties to collect or share your personal data. We have no control these third-party websites, plug-ins or applications and are not responsible for their privacy notices, therefore you should also read their privacy notices to understand what personal data they collect about you and how they use it.
- The data we collect about you
Part 1 of Schedule 1 lists the types of personal data we may process.
We also collect, use and share aggregated data. However, if we combine aggregated data with your personal data so that it can directly or indirectly identify you, we treat this as your personal data.
We do not collect any special categories of personal data or any information about criminal convictions and offences.
Failure to provide personal data
If we are required by law, or under the terms of a contract we have with you, to collect your personal data and you fail to provide it, we may not be able to enter into perform the contract with you and, we may have to cancel a product or service. We will notify you of this at the relevant time.
- How personal data is collected
We collect personal data in the following ways:
| Direct interactions | You may provide personal data when you complete online forms, request products/services, join our mailing list or otherwise use any interactive services on our website which involve the submission of your personal data or where you correspond with us (by post, phone or email). |
| Automated technology | We automatically collect personal data (technical and usage) when you browse or interact with our website, by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites which use our cookies. Please see our cookie policy for further details. |
| Publicly available sources | We may collect personal data from publicly available sources such as Companies House, the Electoral Register and credit reference agencies based inside the EU, and LinkedIn which is based outside the EU. |
| Third parties | We may receive personal data from: (a) analytics providers; (b) advertising networks; and (c) search information providers; (d) our suppliers such as website support and maintenance providers (and in each case, these third parties may be based outside or inside the EEA). |
- How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data:
- to perform the contract we are to enter into or have entered into with you;
- to comply with a legal obligation; and
- where it is necessary to carry out our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Part 2 of Schedule 1 sets out the lawful basis we will rely on to process your personal data.
We do generally only rely on consent as a legal basis for processing your personal data to send email marketing communications and you have the right to withdraw your consent at any time by contacting us.
We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your information.
Marketing
Generally, you will only receive marketing communications from us if you have requested information from us, purchased products/services from us or if you consent to marketing at the time we collect your personal data and you have not subsequently opted out or withdrawn your consent or if we have another basis to send you the marketing communications (which includes “soft opt-in” where we have provided products to you in the past and you have not opted-out).
We may also market directly to you where we have legitimate interests to do so and we are not prevented by any other applicable data protection or marketing laws.
How to opt out
You can opt out of email marketing by clicking the unsubscribe button within the particular marketing email. You can also withdraw your consent to marketing at any time by contacting our DPM.
Even if you opt out of receiving marketing, we may still use your personal data for other purposes provided we have a lawful basis to do so.
Change of purpose
We will only use your personal data for the purpose that we originally collected it for, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to use your personal data in this manner.
We may process your personal data (without your knowledge or consent) where this is required or permitted by law.
- Disclosure of your personal data
We may have to share your personal data with third parties further details of which are set out in Part 4 of Schedule 1. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes. They can only process your personal data for specified purposes and in accordance with our instructions.
- International transfers
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, 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.
- we use specific contracts approved by the European Commission which give personal data the same protection it has in Europe with our services providers;
- we may transfer data to US based service providers under the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
- Data security
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. We also limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know and they can only process your personal data on our instructions and will be subject to a duty of confidentiality.
We have procedures in place 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.
- Data retention
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.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us. However, we are legally required to keep basic information about our customers (including contact, identity, financial and transaction data) for six years after they cease being customers, for tax purposes.
We may also anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes. We can use anonymised information indefinitely without further notice to you.
- Your legal rights
Your legal rights in relation to your personal data are set out in Part 3 of Schedule 1. If you wish to exercise any of your rights, please contact our DPM.
You will not have to pay a fee to exercise any of your rights. However, if your request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee for this information or refuse to comply with your request.
We may ask you to provide further information to help us confirm your identity. This is a security measure to ensure that personal data is not disclosed to any person who does not have the right to receive it.
We aim to respond to requests within one month. If your request is particularly complex or you have made a number of requests it may take us longer to respond. In this case, we will notify you and keep you updated.
- Types of personal data
| contact data | postal address, email address and telephone number |
| identity data | first name, last name, job title |
| marketing and communication data | your preferences in receiving marketing from us and our group members and your communication preferences |
| profile data | your interests, preferences, feedback and details of any downloads |
| technical data | 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 our website |
- Lawful basis for processing and processing activities
The lawful basis upon which we may rely on to process your personal data are:
| consent | you have given your express consent for us to process your personal data for a specific purpose. |
| contract | the processing is necessary for us to perform our contractual obligations with you under our contract, or because you have asked us to take specific steps before entering into a contract with you. |
| legal obligation | the processing is necessary for us to comply with legal or regulatory obligation. |
| legitimate interests | the processing is necessary for our or a third party’s legitimate interest e.g. in order for us to provide the best service to you via our website. Before we process your personal data on this basis we make sure we consider and balance any potential impact on you, and we will not use your personal data on this basis where such impact outweighs our interest. |
Set out below are specific details of the processing activities we undertake with your personal data and the lawful basis for doing this.
| Purpose/Activity | Type of data | Lawful basis for processing |
| to register your interest in our services | identity & contact | legitimate interests and consents |
| to manage our relationship with you, notifying you about changes to our Terms or Privacy Notice and ask you to leave a review or take a survey | identity, contact, profile & marketing & communications | (i) to perform our contract with you
(ii) as necessary to comply with a legal obligation (iii) as necessary for our legitimate interests in keeping our records updated and analysing how customers use our products/services. |
| to administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | identity, contact & technical | (i) as necessary for our legitimate interests in running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise
(ii) as necessary to comply with any legal obligations |
| to deliver relevant website content/advertisements to you and measure or understand the effectiveness of our advertising | identity, contact, profile, usage, marketing & communications & technical | as necessary for our legitimate interests in studying how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy |
| to use data analytics to improve our website, products/services, marketing, customer relationships and experiences | technical & usage | as necessary for our legitimate interests to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy |
| to make suggestions and recommendations to you about goods or services that may be of interest to you, including promotional offers | identity, contact, technical, usage & profile | as necessary for our legitimate interests to develop our products/services and grow our business |
- Your legal rights
You have the following legal rights in relation to your personal data:
| access your data | you can ask for access to and a copy of your personal data and can check we are lawfully processing it |
| correction | you can ask us to correct any incomplete or inaccurate personal data we hold about you |
| erasure | you can ask us to delete or remove your personal data where:
We may not always be able to comply with your request for specific legal reasons, which will be notified to you at the time of your request. |
| object | you can object to the processing of your personal data where:
In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms and in such circumstances, we can continue to process your persona data for such purposes. |
| restrict processing | you can ask us to us to suspend or restrict the processing of your personal data, if:
|
| request a transfer | you can request a transfer of your personal data which is held in an automated manner and which you provided your consent for us to process such personal data or which we need to process to perform our contact with you, to you or a third party. We will provide your personal data in a structured, commonly used, machine-readable format. |
| withdraw your consent | you can withdraw your consent at any time (where we are relying on consent to process your personal data). This does not affect the lawfulness of any processing carried out before you withdraw your consent. |
- Third Parties
| group companies | other companies in the GDM Investment Holdings Limited Group acting as joint controllers or processors and who are based in England and provide IT and system administration services and undertake leadership reporting |
| service providers | acting as processors who provide IT and system administration services |
| professional advisors | acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services |
| HM Revenue & Customs, regulators and other authorities | acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances |
| third parties | third parties whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice |
| analytics and tracking companies | acting as processors who provide analytics and tracking software |
- Glossary
| aggregated data | information such as statistical or demographic data which may be derived from personal data but which cannot by itself identify a data subject |
| controller | a body that determines the purposes and means of processing personal data |
| data subject | an individual living person identified by personal data (which will generally be you) |
| personal data | information identifying a data subject from that data alone or with other data we may hold but it does not include anonymised or aggregated data |
| processor | a body that is responsible for processing personal data on behalf of a controller. |
| special categories of personal data | information about race, ethnicity political opinions, religious or philosophical beliefs, trade union membership, health, genetic, biometric data, sex life, sexual orientation. |
| ICO | Information Commissioner’s Office, the UK supervisory authority for data protection issues. |