Thank you for visiting our website www.pumainvestments.co.uk (the “Website”).
This Privacy Statement (the “Privacy Statement”) describes how we handle your personal information.
The Website is owned and operated by Puma Investment Management Limited (“Puma Investments, “us”, “our” and “we”).
Bell Pottinger provides and hosts the Website. Bell Pottinger is registered with the UK Data Commissioner and holds within the UK the personal information we collect.
Personal information which we collect
We ask our clients to provide personal information. The types of information collected include name, address and email address, phone number, company and job title.
We may also request further information from users so that we may provide them with access to subscription or other services. The information we request enables us to provide and monitor on-going use of those services.
If you contact us through this site regarding employment opportunities, we may request a copy of your CV and personal details relating to your employment application. That information will be used for the purpose of assessing your application and we ensure that its collection and use is in accordance with this Privacy Statement and our obligations under data protection laws.
We use “cookies” and have a Cookies Policy which can be accessed here.
Our Website logs your IP address and other information about your computer for administrative and security reasons and to collate statistical (non-personal) information about the use of our Website.
What we do with your information
We use the information we collect from you:
• for everyday business purposes;
• to evaluate, analyse and improve our business;
• to assess trends and usage of this website;
• to review and analyse your use of our products and services; including account transaction, to help protect you from unauthorised use of your accounts;
• to help us better serve you and our clients;
• to bring other products and services of interest to your attention;
• where applicable, to verify your information with employers or other referees;
• to comply with relevant laws and regulations.
We may also collect and analyse information from other sources for the same purposes.
Clients may also be asked to provide additional information in order to:
• establish identification;
• help protect from error and fraud;
• provide on-going services; and
• meet legal regulatory requirements.
If Puma Investments enters into business with or is sold to or merged with another business entity, your information may be disclosed to our new business partners or owners who may then provide you with information on their products or services.
You may always opt out of hearing from these parties by emailing or writing to us at the contact given at the end of this Privacy Statement.
Who we may share the information with
We obtain client consent before we:
· offer clients other products and services;
· send client’s information about products and services through direct marketing. We may keep you informed of any activities undertaken by us which we believe may be of interest to you and this use may include email, postal and SMS marketing from time to time. If at any time you wish to opt out of receiving such direct marketing materials, you can do so by contacting our Compliance Officer on the contact details at the end of this Privacy Statement;
· share information about clients with our service providers or offer it to parties outside Puma Investments;
· disclose to other persons information about our clients unless we must disclose information for legal reasons. We may be required to release information by a court of law, or other legal or regulatory authorities or agencies. If so, our guideline is to release information only to the extent required and to ensure that the relevant governmental or regulatory agency has invoked the appropriate authority, forcing us to release information we have about the client.
However, we may collect, use or disclose information without client consent if we must:
· carry out a risk assessment or must perform a necessary credit check; or
· disclose information in order to carry out investment services. For example, including but not limited to: disclosure to Custodians or Registrars.
By registering to use our site, clients consent to their details being used by us and disclosed by us to the FCA if and when requested. Clients may withdraw their consent in writing at any time, provided no legal requirements exist to prevent this. However, if the clients do not consent to certain uses of information, or if they withdraw their consent (“opt out”), we may not be able to provide them a particular product or service.
Transfers outside the EEA
Except as set out above, we will not share information about clients with anyone outside the Puma Investments or the Shore Capital group. However, some affiliates of Puma Investments within the Shore Capital group may be outside the European Economic Area. Some of these countries may not always have strong data protection laws. However, we will always take steps to ensure that personal information relating to clients is used by third parties in accordance with this Privacy Statement and that it is kept secure. If you do not consent to this transfer then please do not subscribe as a registered user as we will be unable to provide you with our services.
How you can request access to your information
In accordance with your rights under the Data Protection Act, you may request the amendment of the personal information we hold. Clients may have access to their personal data (i.e. legal entity names and addresses, phone and fax numbers, email addresses, physical and trading addresses, contact names, etc.). Clients may check their account information for verifications, updates, corrections and to delete obsolete information. If you wish to obtain a copy of this information, update or correct your details or remove your personal data from our records, please contact us at firstname.lastname@example.org.
Our Website has security measures in place to protect against the loss, misuse and alteration of the personal information under our control. We protect our clients’ privacy by:
· keeping client information and their business in the strictest confidence;
· controlling how we obtain, use and give out information;
· respecting our clients’ privacy when marketing our products and services; and
· taking steps to adhere to our obligations and to protect our clients’ rights under data protection laws.
We take steps to protect our client’s information from error, loss and unauthorised access. Members of staff with access to client information are aware of the need to maintain confidentiality. Each staff member signs an agreement stating that they are aware of their duties and responsibilities under the Data Protection Act 1998 and that maintaining confidentiality is a contractual condition of employment or membership. Our IT department act to ensure security measures are in place to protect client information at all times; whether stored in data files or utilised by our staff.
Bell Pottinger adheres to industry standards in relation to security measures for protecting personal and client details.
Retention of information
We will only hold the minimum personal information necessary and for the minimum amount of time. We will only keep any information on record for the time period specified by law.
Updates to Privacy Statement
If you have any questions relating to this Privacy Statement then please contact our Compliance Officer:
Puma Investments, Bond Street House, 14 Clifford Street, London W1S 4JU
Telephone: +44 (0) 20 7408 4050