This website is provided by TAM Asset Management Limited, who 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 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. The policy does not cover any external third-party websites that may be accessed through the links provided on our website.
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 and visitors to our website, namely:
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 Independent Financial Adviser (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 receive 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:
The types of personal data we might collect and process
We may collect and process the following data:
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:
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:
TAM will not lend or sell your information to third parties, but we may provide access to your personally 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:
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.
What are Cookies?
Cookies are used on almost every website and are text files containing small amounts of information, which your computer or mobile device downloads when you visit a website. When you return to these websites – or visit other websites that use the same cookies – they recognise these cookies and therefore your browsing device. For further information on cookies, visit www.aboutcookies.org or www.allaboutcookies.org
You can disable cookies on your computer by indicating this in the ‘options’ or ‘preferences’ menus in your browser. However, it is possible that some parts of our website will not operate correctly if you disable cookies. Should you have any questions regarding disabling cookies, the above websites will advise you how to remove cookies from your browser. You can also consult with your browser’s provider.
The cookies collect information in an anonymous form, including the number of visitors to the site, what pages they have visited. which enable us to compile reports and to help us improve the website.
Cookies used by the TAM website DO NOT:
What types of cookies do we use
We use three main types of cookies on our website:
Links to sites provided by others
If you follow a link from our website to another website, please be aware that the owner of the other website will have their own privacy and cookie policies for their site. We therefore recommend that you read their policies as we are not responsible or liable for what happens at their site.
Using browser settings to manage cookies
Most web browsers allow you to manage cookies via the browser settings. For example, you may choose to delete existing cookies, prevent your browser from accepting new cookies, have the browser notify you when you receive a new cookie or disable cookies altogether.
You can control how cookies are placed on your device and remove existing cookies by changing your web browser settings.
Head of Legal & Compliance
TAM Asset Management Limited
40 Basinghall Street
London EC2V 5DE
Date of Issue: 25th May 2018