What data privacy principles does the Firm adhere to
We will process all personal data in a lawful, fair and transparent manner;
We will only collect personal data where it is necessary;
For the Firm to provide a service to you;
For you to provide a service to the Firm;
For the Firm to keep you informed of its products and services; or
For the Firm to comply with its legal and regulatory obligations.
The personal data collected by the Firm will be adequate, relevant and limited to what is necessary in relation to the specific purpose for which your data will be processed;
We will take all reasonable steps to ensure that personal data is accurate and, where necessary, kept up-to-date;
We will maintain personal data in a form that permits identification for no longer than is necessary for the purposes for which the personal data has been collected for processing, in accordance with the Firm’s record retention requirements as mandated by the Financial Conduct Authority;
We will hold and process personal data in a manner that ensures appropriate security;
We will only share personal data where it is necessary to provide the agreed service or where it is necessary for the Firm to comply with its legal and regulatory requirements.
We will only utilise a service provider based outside of the EEA for the processing of personal data where this is strictly necessary to facilitate our services to you. In all cases, we will ensure service providers are fully compliant with GDPR ahead of transferring any personal data.
What type of information do we collect from you
In the course of providing products or services to you, we may collect information that is considered personal; we may collect and process the following information from you:
Information that you provide by filling in forms on our website www.latitudeim.com (our Website); e.g. your name, address, email address and phone number.
If you contact us, we may keep a record of that correspondence; and
Details of your visits to our Website and the resources that you access.
IP Addresses and Cookies
We may also collect information about your computer, including where available your IP address, operating system and browser type, for system administration purposes.
Cookies contain information that is transferred to your computer's hard drive. Cookies allow a web application to tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
This statistical data does not identify an individual. We only use this information:
to gather information on IP addresses and pages visited;
to analyse trends;
to administer the website;
to track users’ movements on the website; and
for purposes of statistical analysis.
How do we use your personal data
We use information held about you in the following ways:
to carry out our obligations arising from any contracts entered into between you and us;
to provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purpose
to ensure that content from our Website is presented in the most effective manner for you and for your computer; and
to notify you about changes to our service.
We may also use your data, or permit selected third parties who work on our behalf to provide a product or a service to you;
If you do not want us to use your data in this way please indicate in the relevant box situated on the form.
How we protect your data
Your right to access your information
Once you have provided your details to the Firm, you have certain rights which apply, depending on your relationship with the Firm, the information you have shared with us and the Firm’s legal and regulatory obligations.
You have the right to request a copy of the information that we hold about you. If you would like a copy of some, or all, of your personal information, please email the Firm at firstname.lastname@example.org. The Firm will provide this information to you within one month (with the ability to extend this by an additional two months where necessary), free of charge.
You have the right to request that the information the Firm holds about you is erased under certain circumstances including where there is no additional legal and/or regulatory requirement for the Firm to retain this information.
As a client, you have the right to request that any information the Firm holds about you be provided to another company in a commonly used and machine-readable format, otherwise known as ‘data portability’.
You have the right to ensure that your personal information is accurate and up to date, or where necessary rectified. Where you feel that your personal data is incorrect or inaccurate and should therefore be updated, please contact email@example.com.
You have the right to object to your information being processed, for example for direct marketing purposes.
You have the right to restrict the processing of your information, for example limiting the material that you receive or where your information is transferred.
You have the right to object to any decisions based on the automated processing of your personal data, including profiling.
You have the right to lodge a complaint with the Information Commissioner’s Office if you are not happy with the way that we manage or process personal data.
How long does the Firm retain personal data
As a regulated entity, the Firm is required to maintain its books and records for a prescribed period (five years from either the ceasing of a business relationship, or, in the case of non-clients, from the making of a record – or alternatively, for seven years, where specifically requested to do so by the Financial Conduct Authority). As such, information that falls in scope of either of these requirements is retained in line with the mandated timeframe.
Any information that is outside the scope of this requirement will be retained whilst relevant and useful, and destroyed where this ceases to be the case or where the data subject specifically requests this.
How have I been categorised in accordance with GDPR
The GDPR requires the Firm to inform you of the legal basis on which we maintain your personal data. Typically, the Firm will reach out to you personally to confirm this; however, as a general rule the following is applicable:
Clients – Information is maintained on the basis of contractual obligation and/or legitimate interests (where relevant);
Service providers – Information is maintained on the basis of contractual obligation; and
From time to time, Latitude Investment Management LLP may send you emails, email newsletters or news updates alerting you to new features, products, promotions, or services pertaining to our Website. If you no longer wish to receive materials from us and/or from such third parties, you may opt-out of receiving these communications by writing to us at Latitude Investment Management LLP, 12-13 St James’s Place, London SW1A 1NP or by emailing us your request to unsubscribe to firstname.lastname@example.org. Latitude Investment Management LLP’s Data Protection No. is ZA188320 or you can contact the ICO on www.ico.org.uk.