ARC PRIVACY STATEMENT

Who we are

Asset Risk Consultants Limited, a Guernsey non-cellular company with registration number: 30293 ("ARC", "our", "us" and "we"), is the operator and copyright holder of all the websites operated by entities in the ARC Group, including but not limited to www.assetrisk.com and www.suggestus.com ("websites").

The Data Controller (Data User) is ARC. ARC can be contacted by e-mail at contactguernsey@assetrisk.com or by telephone on +44 1481 817777.

ARC's Data Protection Officer, David Bartlett, can be contacted at the e-mail address or telephone number of ARC specified above.

ARC is an independent investment consultant and investment manager research group.

We are registered under the Data Protection (Bailiwick of Guernsey) Law, 2017 (as amended) (the "Law") with the Office of the Data Protection Authority of Guernsey ('ODPA'). The ODPA's address is Block A, Lefebvre Court, Lefebvre Street, St Peter Port, Guernsey GY1 2JP and the ODPA can be contacted by telephone on +44 (0)1481 742074 or by email at info@odpa.gg. You have a right to complain and if you feel that we have not met our obligations please contact us in the first instance or, alternatively, you may approach the ODPA.

Your Consent

ARC is committed to protecting your data and guarding your privacy. When you register on the ARC website (www.suggestus.com) you make a free and active choice that you agree to the collection and use of your personal data, as set out in this privacy statement. Please do not register if you do not agree to or do not understand the use of your data in this way.

What Personal Data do we collect?

1. General

This privacy statement explains what ARC does with personal data. All personal data provided to us is handled in accordance with the Law and this privacy statement. By using our websites and subscribing to services provided by ARC (including free information services), you actively and freely consent to us using your personal data in the ways we have set out below. Some areas of our websites might ask you to register with us and to provide personal data before we will provide certain information or make certain services available to you. We ask for this information for several reasons. These reasons include:

(a) to build your user profile;
(b) to enable us to understand our users’ needs better;
(c) to collect aggregate information about users’ needs and behaviour;
(d) to provide more tailored products and services to you;
(e) to provide you with information about products, services, seminars and events which we offer; and
(f) to audit usage of our websites.

You are not required to give us this information but, if you do give it to us, this will be treated as consent on your part to us contacting you and collecting information for these purposes.

2. Data we collect

We may collect and process the following data about you:

  • (a) Information you give us. You may give us information actively about yourself by filling in forms on our sites www.assetrisk.com or www.suggestus.com (our "Sites") or by corresponding with us by phone, e-mail or otherwise. That includes information you provide when you register to use our Sites, subscribe to our services, search for a product, enter a survey and when you report a problem with any of our Sites. The information you give us may include your name, address, e-mail address and phone number, financial information and personal description. Such actively provided information is used to create your User Profile. In some cases, if you fail to provide the requested personal data we shall be unable to provide the service you request.
  • (b) Information we collect about you. With regard to each of your visits to our Sites we may automatically, through cookies and similar means, collect the following information passively provided by you:
    • (i) technical information, including the internet protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
    • (ii) information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Sites (including date and time); services you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call us.
  • (c) Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. In this case we may share data that we have collected internally and combine it with data collected on our Sites. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.

If you provide information to us in relation to another person, you must have the express consent of that person before such information is provided to us.

You have the "right to be forgotten" if you request. We shall then delete your personal data other than that required to be maintained for regulatory purposes.

3. How we use data

By registering and consenting to ARC using the personal data provided by you requires you to understand how we use that data. If you do not consent to such usage do not use our websites.

ARC will use your user profile personal data to ensure that our service or marketing, directed to you by whatever means (e.g. post, telephone or e-mail), is relevant and informative.

4. Third Party Usage

ARC will never sell or pass on our databases to enable third parties to market their products or services directly to you.

Please note that we may pass your details to third parties engaged by us or with whom we work in the following circumstances:

  • (a) If you have been granted access to the investment manager research facilities of the Site, your accessing of materials related to a particular manager is logged and your name, email address and Site activity is accessible to that manager. The manager may use that information for marketing purposes where lawfully permitted to do so.
  • (b) If you are a client, we may pass your personal data to a third party. We might wish to do this for a number of reasons, such as to enable us to carry out work for you, for training purposes and/or for credit control purposes;
  • (c) ARC may need to pass your personal data on to a third party in relation to the holding and management of an event, in which case the information will only be used by that third party for that specific purpose; or
  • (d) Where services to ARC are provided by an external provider. For example, we have arrangements in place with service providers in relation to IT systems and support, document creation and management and research services.

Save as set out above, any information which ARC holds or collects will not be disclosed to third parties, except as required or permitted by law or any regulatory body. The act of registering on an ARC website confirms your consent for ARC to use your personal data 'for profit'. You may 'opt out' or withdraw your consent for us to use your personal information for any of the purposes outlined in this privacy statement at any time by emailing Privacy@suggestus.com or calling 01481 817777.

If you wish to cease receiving material from Citywire Financial Publishers Ltd please contact them directly at privacy@citywire.co.uk or call 020 7840 5100.

5. Where we store data

The data that we collect from you may be transferred to, and stored at, a destination within the Island of Guernsey, the Island of Jersey or the European Economic Area (together, the "Channel Islands and EEA"). It may also be processed by staff, operating inside the Channel Islands and the EEA, working for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your services, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with the Law and this privacy statement.

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

6. Change of Ownership

In the event of a re-organisation, change in ownership, or transfer of all or part of our business, we reserve the right to transfer all of ARC's data, including personal information, to a new entity or to third parties through which the business of ACR will be carried out. We will use all reasonable efforts to notify you of such change by posting on one or both of the websites or via an email sent to the email address you provide.

7. Cookies

We may collect some information passively from your use of our websites through 'cookies'. Cookies are temporary internet files which are placed on your computer’s hard drive by your internet browser. These allow us to collect information such as the time spent on our website, means of entry/exit and the pages used. They help us improve our websites and deliver an effective service. Most browsers have a facility that allows you to disable cookies – please refer to your browser’s help menu to find out how to do this. Although you will still be able to browse through most of our websites, when cookies are disabled certain features may not be available.

8. Your Rights

You are entitled to obtain from us details concerning the processing of your personal information. This includes details of the data being processed, the purposes of the processing, any recipients of that information, the period for which the information is processed, the source of the information (if it is not provided by you), any international transfers of the information and the protections we put in place to protect your information. You are also entitled to details of any automated decision-making, including profiling, involving your information.

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at Privacy@suggestus.com.

You are entitled to ask for a copy of the personal information we hold on you (including in electronic form) and to ask for any inaccuracies to be corrected. Please do so by emailing Privacy@suggestus.com. Additional copies may be subject to a reasonable administrative fee.

Where you provide personal information to us and consent to us using it and the processing is carried out by automatic means you are entitled to receive a copy of that information in a machine-readable format and for that to be provided to another data controller, where technically possible.

In certain circumstances you are entitled to have personal information erased, including where this is no longer necessary for the purposes for which it was collected and/or processed; or you withdraw consent to our use of the information. We may continue processing the information in certain circumstances, including: if there are grounds other than consent for processing the information; where processing is in compliance with a legal obligation or for reasons of public interest; or for the exercise or defence of legal claims. If you request that we erase your personal information we shall advise you if we consider that there are on-going grounds permitting us to continue processing your information.

You can ask us to restrict the processing of personal information ARC holds about you if: you contest the accuracy of the personal information we process about you; you consider that the processing is unlawful but you do not want us to erase the information; we do not require to continue processing the information but you wish the information to be retained in connection with a legal claim; or you have objected to the grounds upon which we process the information. Where you have asked us to restrict processing the information we shall only hold, process and erase the information as permitted by you or as permitted by applicable data protection laws. We will advise you if we do not agree with your request to restrict processing and our reasons.

Our Sites may, from time to time, contain links to and from the websites of our business partners, advertisers and affiliates. If you follow a link to any of those websites, please note that those websites have their own privacy statements and that we do not accept any responsibility or liability for those statements or your use of those websites. Please check those privacy statements before you submit any personal data to those websites.

9. Communication

To make sure that we follow your instructions correctly, and to improve our service through training of our staff, we may monitor any communication between you and us. If your personal details change, if you change your mind about any of your marketing preferences or if you have any queries about how we use your information, please let us know at Privacy@suggestus.com.

10. Our Obligations

We have a regulatory obligation to ensure that the information we hold on you is accurate and up-to-date. As such we shall keep in contact with you to ensure that remains the case.

If any of your information has changed please contact Privacy@suggestus.com and we shall update your details. By using our Sites you are confirming that the information provided is accurate and up to date and that we may use such information in meeting our obligations to regulators and anyone empowered to require such information by law. This privacy statement is issued to comply with our requirements under the Law and we may change it from time to time and you should therefore review it regularly. However, if we make any substantial changes we will notify you by posting a prominent announcement on our Sites.

You can update your personal information or preferences on our website using your login and password. You can also unsubscribe in the same way or by emailing Privacy@suggestus.com.

ARC will retain your information for the duration of the service we provide to you, including the life of any index in which it is included and the duration of any legal obligations we have to hold your information.

11. Updates

This privacy statement may be updated from time to time and was last updated on 7th August 2024. The current version of this privacy statement shall be displayed at this page on the Suggestus website or may otherwise be requested at Privacy@suggestus.com.

If you would like to access previous versions of this policy please contact us at Privacy@suggestus.com.

Last updated 07/08/2024