Please read our privacy and cookies policy along with the references in full.
If you do not agree to anything in the policy or the references then please leave our websites immediately.
P1.1 We are committed to safeguarding the privacy of our website visitors and service users.
This policy can be used as a guide to aid understanding of how our practices collect and use data and it allows you to make informed choices about using our products and/or services.
P1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data. By using our websites you are agreeing to the use of your data as described by this privacy and cookies policy.
P1.4 Any website forms incorporate privacy controls which affect how we will process your personal data. By using the privacy controls on the forms, you can specify whether you would like to receive direct marketing communications.
P1.5 In this policy, “we”, “us” and “our” refer to Pilling & Co. Stockbrokers Ltd. and our technology service providers. For more information about us, see Section P19.
P1.6 This policy must be read in conjunction with our General Terms & Conditions of Business, specifically Section 26 “How we use your data”. This includes full details of how and why we process your data and information, including ‘special categories’ of data.
P1.7 At any time you may withhold or withdraw consent for use of your data but this may affect the products and/or services available to you.
P1.8 This policy applies to all data including personal information, submitted to us either electronically or in any other document form while using our websites.
P1.9 The types of information or personal information we may process, store and/or transport, may consist of, but is not limited to in electronic or other document form as described in P2.
P2. HOW WE USE YOUR PERSONAL DATA
P2.1 In this Section P2 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
P2.2 We may process data about your use of our websites and services (“usage data”). The usage data may include your Internet Protocol (IP) address, geographical location, browser type and version, device type, operating system and version, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data are webservers and analytics tracking systems. This usage data may be processed for the purposes of analysing the use and efficiency of the websites and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our websites and services.
P2.3 We may process your account data (“account data”). The account data may include but is not limited to: title, job title, initials, name, date of birth, postal address, email address, phone number, fax number, mobile number, passport details, account information, bank account information, payment account information, credit or debit card information, cheque information, email contents and our replies, postal mail, faxes, telephone call logs and recordings, document scans and any other information you may provide to us including dates and times of requests or submissions.
The source of the account data is you. The account data may be processed for the purposes of operating our websites, providing our services, ensuring the security of our websites and services, maintaining backups of our databases and communicating with you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
P2.4 We may process your information included in any personal profile or comment sections on our websites (“profile data”). The profile data may include your name, profile pictures, social media content, gender and high-level location information. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is consent.
P2.5 We may process your personal data that are provided in the course of the use of our services (“service data”). The service data may include name, username, password, access logs, document downloads and document uploads, email address and postal address. The source of the service data is you. The service data may be processed for the purposes of operating our websites, providing our services, ensuring the security of our websites and services, maintaining backups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
P2.6 We may process information that you post for publication on our website or through our services (“publication data”). The publication data may be processed for the purposes of enabling such publication and administering our websites and services. The legal basis for this processing is consent.
P2.7 We may process information contained in any enquiry or form you submit to us regarding goods and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.
P2.8 We may process information relating to our customer relationships, including customer contact information (“customer relationship data”). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships.
P2.9 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our websites (“transaction data”). The transaction data may include your contact details, your financial payment details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our websites and business.
P2.10 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”) for example Client Web Access (CWA) alerts and PEP/ISA Talk newsletters. The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
P2.11 We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our websites and business and communications with users.
P2.12 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
P2.13 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
P2.14 In addition to the specific purposes for which we may process your personal data set out in this Section P2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
P2.15 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
P2.16 Should you communicate with us in an offensive, inappropriate, objectionable, defamatory or disruptive manner we may use your information to stop any such communication.
P3. AUTOMATED DECISION-MAKING
P3.1 We will not use your personal data for the purposes of automated decision-making.
P4. PROVIDING YOUR PERSONAL DATA TO OTHERS
P4.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
P4.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
P4.4 Financial transactions relating to our websites and services may be handled by our technology services providers. We will share transaction data with our technology service providers only to the extent necessary for the purposes of processing transactions and dealing with complaints and queries relating to such transactions.
P4.6 In addition to the specific disclosures of personal data set out in this Section P4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
P4.5 Data may be handled by our technology services providers. We will share your data with our technology service providers only to the extent necessary for the purposes of providing services to you and dealing with complaints and queries. Some of these providers may involve the transfer of data to countries with different or no data protection laws compared to that of the UK.
P5. INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA
P5.1 In this Section P5, we provide information about the circumstances in which your personal data may be transmitted to countries outside the European Economic Area (EEA).
P5.3 The hosting facilities for our websites and services are situated in the UK however due to the interconnected nature of the internet it is not possible to guarantee that data in transit through communication bearers does not utilise communications systems outside the UK or the European Economic Area (EEA).
P5.5 You acknowledge that personal data that you may submit for publication through our websites or services will be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
P6. RETAINING AND DELETING PERSONAL DATA
P6.1 This Section P6 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
P6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
P6.3 We will retain your personal data during the performance of a contract between you and us and as long as we need to fulfil the relevant purpose(s) it was collected for and as above in P2.
P6.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on legal, regulatory and/or where we have a legitimate reason in doing so.
P6.5 Notwithstanding the other provisions of this Section P6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
P7. SECURITY OF PERSONAL DATA
P7.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
P7.2 We will store your personal data on access controlled servers, computers, mobile devices, and in manual record-keeping systems.
P7.3 The following personal data will be stored by us in encrypted form: your account password credentials.
P7.4 Data relating to your enquiries and transactions that is sent from your web browser to our webservers, or from our webservers to your web browser, will be protected using industry standard encryption technology.
P7.5 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
P7.6 You should ensure that passwords are not susceptible to being guessed, whether by a person or an automated system. You are responsible for keeping the passwords you use for accessing our websites confidential and we will not ask you for your password (except when you log in to our websites e.g. CWA).
P8.1 We may update this policy from time to time by publishing a new version on our websites.
P8.2 You should check this page regularly to ensure you are happy with any changes to this policy.
P8.3 We may notify you of changes to this policy by email, postal service or through the CWA private messaging system.
P9. YOUR RIGHTS
P9.1 In this Section P9, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
P9.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
P9.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. Additional copies may be subject to a reasonable fee. You can access some of your personal data by visiting CWA when logged into our website.
P9.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
P9.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
P9.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
P9.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
P9.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
P9.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
P9.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
P9.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
P9.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
P9.13 You may exercise any of your rights in relation to your personal data by written notice to us in addition to the other methods specified in this Section P9.
P10. THIRD PARTY WEBSITES
P10.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
P11. PERSONAL DATA OF CHILDREN
P11.1 Our website and services are targeted at persons over the age of 18.
P11.2 If we have reason to believe that we hold personal data of a person under that age in our databases which is not required for the performance of a contract between you and us, we will delete that personal data.
P12. UPDATING INFORMATION
P12.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
P13. ACTING AS A DATA PROCESSOR
P13.1 In respect of selected providers which we work with for the performance of a contract between you and us we do not act as a data controller; instead, we act as a data processor.
P13.2 Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller.
P14. ABOUT COOKIES
P14.1 A cookie is a small file containing an identifier(s) (strings of letters and numbers) that is sent by a webserver to a web browser and is stored by the browser. The identifier(s) is then sent back to the server each time the browser requests a page from the server.
P14.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
P14.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
P15. COOKIES THAT WE USE
Further details about the cookies we use are at P16.5.
P16. COOKIES USED BY OUR SERVICE PROVIDERS
Note: Google Analytics does not store any personal information about users. To opt-out of Google Analytics across all websites you visit please read the external Google page at https://tools.google.com/dlpage/gaoptout.
Further details about the cookies used and their names are at P16.5.
P16.4 ‘First’ and ‘Third Party’ Cookie types refer to the webserver domain placing the Cookie. Cookies set by one of our webserver domains are called ‘First Party’ Cookies. ‘Third Party’ Cookies are set by a webserver domain other than the one directly being visited – and we cannot control the use settings of these e.g. where external content embedded in our webpages may utilise other service providers (e.g. News content) and you may therefore receive a Cookie from these providers too.
P16.5 Details about the cookies and their names are described as follows:
|Client Web Access||asp.net_sessionid||End of browser session||Used as session identification within the Client Web Access website. This Cookie contains a session identifier.||First Party Session|
|Client Web Access||.aspxauth||End of browser session||Used as session identification within the Client Web Access website. This Cookie determines that a user is logged in.||First Party Session|
|Client Web Access||welcomepageshow||Upon deletion||Used to show the Client Web Access welcome page and remember user preferences.||First Party Persistent|
|Google Webserver Analytics||_ga / _ga_X||2 years||Used for webserver analytics to distinguish users.||First Party Persistent|
|Google Weserver Analytics||_gat / _gat_gtag_X||1 minute||Used for webserver analytics to throttle request rate.||First Party Persistent|
|Google Webserver Analytics||_gid||24 hours||Used for webserver analytics to distinguish users.||First Party Persistent|
|Important / Legal Notification Prompts||rememberMeXXXX|
(where XXXX is a numeric identifier)
|30 days||A Notification Prompt is used on various parts of our websites to inform you of important / legal information. When you first enter these parts you will see a pop-up notification message and this Cookie is set so that we know you have acknowledged the pop-up so you are not shown it again.||First Party Persistent|
|Important / Legal Notification Prompts||cookielawinfo-checkbox-necessary||1 year||Cookie that keeps track of which cookies you approved.||First Party Persistent|
|Important / Legal Notification Prompts||cookielawinfo-checkbox-non-necessary||1 year||Cookie that keeps track of which cookies you approved.||First Party Persistent|
|ShareThis Service||__unam||1 year||Used with the ShareThis service to monitor activity and allow sharing of content with social media platforms.||First Party Persistent|
P17. MANAGING COOKIES
P17.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain information about blocking and deleting cookies via these links:
(a) Google Chrome: https://support.google.com/chrome/answer/95647?hl=en;
(b) Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences;
(d) Microsoft Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies;
(e) Safari: https://support.apple.com/en-gb/guide/safari/sfri11471/mac; and
(f) Microsoft Edge: https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy.
Please consult the ‘help’ section of your internet device browser instructions for further information about how cookies are used in your particular browser and how you may delete and enable or disable their use.
P17.2 Blocking all cookies will have a negative impact upon the usability of many websites.
P18. OUR DETAILS
P18.1 This website is owned and operated by Pilling & Co. (Stockbrokers) Ltd.
P18.2 We are registered in England and Wales under registration number 9220456, and our registered office is at: Henry Pilling House, Booth Street, Manchester, M2 4AF, UK.
P18.3 Our principal place of business is at: Henry Pilling House, Booth Street, Manchester, M2 4AF, UK.
P18.4 You can contact us:
(a) by post, using the postal address: Henry Pilling House, Booth Street, Manchester, M2 4AF, UK;
(b) by website, using our enquiry page;
(c) by telephone, on 0161 832 6581; or
(d) by email, using email@example.com.
P19. DATA PROTECTION REGISTRATION
P19.1 We are registered as a data controller with the UK Information Commissioner’s Office.
P19.2 Our data protection registration number is ZA107077.
P20. DATA PROTECTION OFFICER
P20.1 Our data protection officer’s contact details are: firstname.lastname@example.org.