At Balkerne Asset Management we’re committed to protecting and respecting your privacy.
This Policy explains when and why we collect personal information about people who visit our website or seek our services, how we use it, the conditions under which we may disclose it to others and how we keep it secure.
We may change this Policy from time to time so please check this page occasionally to ensure that you’re happy with any changes. By using our website, you’re agreeing to be bound by this Policy.
Any questions regarding this Policy and our privacy practices should be sent by email to [email protected] or by writing to Mark Howell at Balkerne Asset Management, 1 Balkerne Hill, Colchester, Essex, CO3 3FG. Alternatively, you can telephone 0808 200 0808.
Balkerne Asset Management is a trading style of Capel Court Plc.
How do we collect information from you?
We obtain information about you when you use our website, and through other legitimate means if you seek to use our services.
What type of information is collected from you?
If you are visiting our website the personal information we collect might include your name, address, email address, IP address, and information regarding what pages are accessed and when.
If you are seeking other services from us we will undertake a ‘suitability assessment’ process. This will include obtaining information, invariably supplied by Capel Court Plc or a third party professional financial adviser, about your personal and financial circumstances and objectives. We will undertake a ‘suitability assessment’ based on the information provided in regard to your Attitude to Risk and Capacity for Loss and record this in our documentation. We will retain records of any other investments or policies that you may have arranged should these be provided to us.
In providing a discretionary management service to you we will update information about you as part of our standard review process and note our records.
Information may be obtained from you via Capel Court Plc, a third part professional financial adviser, face to face, mail & email or completion of online documentation. As the information is required to enable us to provide our services if you opt not to provide it we may not be able to offer or continue to manage your investment portfolio with us.
How is your information used?
We will use your information to:
- Act as the basis for any discretionary management or other services we provide
- To carry out our obligations arising from any contracts entered into by you and us
- Provide information to investment brokers, institutions and service providers for the purposes of arranging and managing the investment portfolio(s) for you
- Provide our ongoing services to you
- Meet our regulatory obligations in the services we provide to you
How long is information retained?
We are required by legislation and the Financial Conduct Authority rules to retain records for specified periods. These vary dependent upon the nature of the service provided. Save for the legislative specified periods, we will hold data for a maximum of 50 years from the date we receive the data.
Who has access to your information?
We will not sell or rent your information to third parties.
We will not share your information with third parties for marketing purposes without your prior consent.
Third Party Investment Brokers, Institutions & Service Providers working on our behalf
We may pass your information to our third party investment brokers, institutions and service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf such as undertaking equity trades, corporate actions or managing income withdrawals from a portfolio. However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own direct marketing purposes. Please be reassured that we will not release your information to third parties beyond the firm for them to use for their own direct marketing purposes, unless you have requested us to do so, or we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime.
For the purposes of anti-money laundering and ID verification checks, Balkerne Asset Management as a trading style of Capel Court Plc specifically utilises the Credit Reference Agency services of TransUnion (formerly Callcredit Limited). In order for you to obtain more details about TransUnion and the information it holds please refer to:
We will make appropriate contact with you to provide the agreed services, including at agreed intervals to undertake an investment review with your prior consent.
We will not contact you for marketing purposes by post, email, phone or text message unless you have given your prior consent. You can change your marketing preferences at any time by contacting us by email: [email protected] or post.
Your rights in relation to your information
The accuracy of your information is important to us. At outset, your personal details, data and information will reflect your situation at that time and we will not normally update this (apart from a change of contact information). However, as we will be providing an ongoing discretionary management service to you we will update the information as appropriate when provided with new and updated information and / or when we undertake an investment review with you. If at any time your personal details or information change, for example a change of address or ban details, please notify us and we will update our records accordingly.
Under new EU requirements you have a number of specific rights, these are summarised below:
Access – You may ask for a copy of the information Balkerne Asset Management hold about you and we will provide this within one month of receipt free of charge (we may charge a fee for subsequent or duplicate requests).
Rectification - You may ask us to correct any information that we hold that is inaccurate or incomplete.
Erasure – You may ask us to delete or cease processing data in certain situations. Please note that we will have regulatory obligations to retain information for certain time periods and we will retain such information as we believe is necessary to fulfil these obligations.
Restrict processing – You may ask us to cease processing information. This means that we will be able to retain it but no longer act upon it. In the event that you no longer need our services and terminate them we will automatically cease processing information.
Portability – You may have the right to have your data transferred to another service provider in an appropriate electronic format. Please note that we will have regulatory obligations to retain copies of the information as outlined previously.
Objection – You may have the right to object to us processing information or using it for marketing purposes.
This is a brief summary of your rights and there may be restrictions on some of them. If you wish to explore any of these rights at any time please contact us and we will be pleased to assist you.
Security precautions in place to protect the loss, misuse or alteration of your information
When you give us personal information, we take steps to ensure that it is retained securely and processed in a confidential manner. Your information may be accessed by employees of Balkerne Asset Management and Capel Court Plc where they were your professional financial adviser for the purposes of providing our services to you. Where Capel Court Plc were not your professional financial adviser, or in accordance with your specific instructions, employees of Capel Court Plc will not have access to your information as held by Balkerne Asset Management. In addition, your information may be accessed by senior managers and our compliance consultants (or the FCA or other regulatory authority) for the purposes of ensuring compliance with our regulatory obligations and reviewing the quality of our advice.
Information may be transmitted normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information that passes between us, and you should consider the risk of this. Once we receive your information, we make our best effort to ensure its secure whilst on our systems. Where we have given (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Use of 'cookies'
It is possible to switch off cookies by setting your browser preferences. Turning cookies off may result in a loss of functionality when using our website.
When you visit our websites we use a cookie to assign you a randomly generated unique identifier. We log your activity on our websites against this identifier in our databases. Once in our databases, this information will be added to your user profile and we use this data to monitor your activity on our website.
Links to other websites
In addition, if you linked to our website from a third party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party site and recommend that you check the policy of that third party site.
Transferring your information outside of Europe
As part of the services offered to you through this website, the information which you provide to us may be transferred to countries outside the European Union (“EU”). By way of example, this may happen if any of our servers are from time to time located in a country outside of the EU. These countries may not have similar data protection laws to the UK. By submitting your personal data, you’re agreeing to this transfer, storing or processing. If we transfer your information outside of the EU in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this Policy.
If you use our services while you are outside the EU, your information may be transferred outside the EU in order to provide you with those services.
Right to complain
If you believe that we are not holding your information correctly or are unhappy about any dealings with us regarding your information you may complain to the Information Commissioners Office. You can do this via their website https://ico.org.uk/concerns or by calling 0303 123 1113.
Review of this Policy