This policy is issued by Mayfair Capital Investment Management Limited ("Mayfair Capital"), a company incorporated in England and Wales under number 04846209, authorised and regulated by the Financial Conduct Authority ("FCA") with FRN 229228 and its registered office is at 2 Cavendish Square, London, W1G 0PU.
Mayfair Capital is committed to safeguarding the personal information which you may provide to us and to the extent that Mayfair Capital collects any personal information, Mayfair Capital will hold it in confidence in accordance with the Data Protection Act 1998 and the General Data Protection Regulation (GDPR) (EU) 2016/679 which comes into force on 25 May 2018.
Information you share with us
You may be asked to voluntarily provide certain personal information details about you such as your name, address, telephone number, email address details and other information in connection with Mayfair Capital's customer or tenant registration procedures. Mayfair Capital will use this information for the administration and servicing of your investments, performing its obligations under lease contracts. and other related activities and to ensure compliance with its obligations under the UK regulatory regime. Mayfair Capital may disclose the information to its agents and service providers.
Please note that by submitting personal information you are consenting to such information being processed for the purposes referred to above. You agree that Mayfair Capital has the right to use and store such data on its internal systems and to transfer it to its associated companies and third- party agents and service providers where applicable, whether inside or outside the European Union to countries having an adequate level of data protection, for the purpose of providing services to you.
Information we collect from you
The Mayfair Capital site collects both behavioural data (information about how you use our site); and technical data (information about the device you use to access our site). Mayfair Capital uses the Google Analytics service provided by Google Inc. (“Google”) to collect this data.
Examples of behavioural data collected:
- Terms entered via our search facility
- Pages visited
- Length of time spent on each page
- The referring site from which you visited
Examples of technical data collected:
- Your web browser type and version
- Your device type and operating system
The site does not collect any data that makes you personally identifiable. The information obtained via Google Analytics is anonymised and cannot be attributed to any one individual. Google Analytics is set to retain data for a duration of 38 months.
Google provides a method to opt out of their Google Analytics service completely. Opting out will prevent Google Analytics from collecting your data from any site that uses their service.
Why we collect this information
This information provides us with a better understanding of how our site is being used. This understanding informs any improvements we undertake and ensures that the site and its content continue to best serve the needs of our visitors.
How we keep data safe
Mayfair Capital adheres to the following practices to help keep the data that we process safe:
- We encrypt and protect the transmission of information using Secure Sockets Layer (SSL).
- We host our site and its contents with Amazon Web Services (AWS) on a secure server within the European Economic Area (EEA).
- We limit server access by Internet Protocol (IP) address to only those that require it.
- We have a server firewall in place that permits only standard inbound internet traffic – HTTP, HTTPS & SSH (restricted by IP).
- We control and regulate access to our Mayfair Capital data files and email accounts.
- We enforce strong passwords and 2 factor authentication (2FA) wherever possible.
Provision of Information to Third Parties
A Data Processor is a third party with which we are required to share personal detail in the provision of investment and property management services. Mayfair Capital will only share personal information in the following circumstances:
- where the transfer is necessary to fulfil the requirements of the contract or operation for which the information was provided, and the third party is a Data Processor;
- as required by a court order or any other legal or regulatory requirement.
Mayfair Capital does not collect or compile personal data or information obtained through the Website for dissemination or sale to outside parties.
We may share your personal information with third party organisations:
- Professional firms, agents and advisers who we use to help run your accounts and services, collect what you owe, administer funds, manage properties and explore new ways of doing business;
- HM Revenue & Customs, regulators and other authorities;
- Third parties as required through Mayfair Capital’s regulatory requirements arising from the provision of investment services;
- Fraud prevention agencies;
- Companies we have a joint venture or agreement to co-operate with;
- Organisations that introduce you to us;
- Independent Financial Advisors, or other regulated entities or parties involved in the management of your relationship with Mayfair Capital; or
- Companies you ask us to share your data with.
We require all third parties with whom we share your personal information to respect the security of your data and to treat it in accordance with the law. We do not allow such third parties to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
Your Rights and Your Personal Data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
- The right to request a copy of your personal data which Mayfair Capital holds about you;
- The right to request that Mayfair Capital corrects any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary for Mayfair Capital to retain such data;
- The right to withdraw your consent to the processing at any time;
- The right to request that Mayfair Capital provide the data subject with his/her personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability);
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- The right to object to the processing of personal data;
- The right to lodge a complaint with the Information Commissioners Office.
How long we keep your Data
We are required under the Markets in Financial Instruments Directive II (MIFID II) rules to retain all client related information for up to 7 years, after which time it will be destroyed. Personal information that we use for marketing purposes will be kept with us until you notify us that you no longer wish to receive this information. After you stop being a client, we may keep your data for up to 7 years for one of these reasons:
- To respond to any questions or complaints;
- To show that we treated you fairly; or
- To maintain records according to rules that apply to us.
We may use your personal information to tell you about relevant products and offers. This is what we mean when we talk about ‘marketing’.
The personal information we have for you is made up of what you tell us, and data we collect when you use our services, or from third parties we work with.
We study this to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you. We can only use your personal information to send you marketing messages if we have either your consent or a ‘legitimate interest’. That is when we have a business or commercial reason to use your information. It must not unfairly go against what is right and best for you. You can ask us to stop sending you marketing messages by contacting us at any time. If at any point you believe the information we process on you is incorrect you can request to see this information and have it corrected or deleted. If you wish to raise a complaint on how we have handled your personal data, you can contact us on the details below to have the matter investigated.
If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.
For the purpose of the Data Protection Act (1998) and the General Data Protection Regulations (GDPR) (EU) 2016/679 the Data Controller is Mayfair Capital Investment Management Limited.
Mayfair Capital is not required to appoint a Data Protection Officer. For more information about our privacy policies or if you have any questions, we welcome your comments. Please contact us at email@example.com, by telephone 020 7495 1929 or by mail:
Mayfair Capital Investment Management Limited
2 Cavendish Square
London W1G 0PU
Last updated: 23 May 2018