TCF Fund Managers, TCF Investment, Multi Asset Portfolio Solutions (MAPS) are all trading styles of TCF Fund Managers LLP. This privacy notice explains how we use any personal information we collect about you.
We collect information about you when you enter into an agreement with us for investment management services.
If you are a customer rather than an adviser:
1. this information will relate to your personal and financial circumstances;
3. we may also collect information when you voluntarily complete client surveys or provide feedback to us.
If you are an authorised adviser:
1. this information will relate to your contact details and information necessary for the provision of our services to you and / or your clients
2. we may also collect information when you voluntarily complete client surveys or provide feedback to us.
If you are an adviser we may also collect contact information about you for the purposes of direct marketing.
Information relating to usage of our website is collected using cookies. These are text files placed on your computer to collect standard internet log information and visitor behaviour information. We may use your information collected from the website to personalise your repeat visits to the site.
As a representative of an authorised adviser you may also establish an account with our website which is required to gain access to additional resources. In this case we collect your contact details, details of your business and record your usage of the website.
If you are a customer who has entered into an agreement with us for investment management services we may need to gather personal information about your close family members and dependants in order to provide our service to you effectively. In such cases it will be your responsibility to ensure that you have the consent of the people concerned to pass their information on to us. We will provide a copy of this privacy notice for them or, where appropriate, ask you to pass the privacy information to them.
If you have entered into an agreement with us the primary legal basis that we intend to use for the processing of your data is for the performance of our contract with you. The information that we collect about you is essential for us to be able to carry out the services that you require from us effectively. Without collecting your personal data we would also be unable to fulfil our legal and regulatory obligations.
Where special category data is required we will obtain your explicit consent in order to collect and process this information.
Where there is not an agreement in place with us or one is not anticipated then the primary legal basis that we intend to use for the processing of your personal information is that of legitimate interest.
We collect information about you in order to provide you with the services for which you engage us.
If there is no agreement between us and you are an authorised adviser we may, from time to time, inform you of our services and send other information which we believe may be of relevance or interest to you. You have the right to object to receiving such information.
If you are a customer rather than adviser and you agree, we may email you about other products or services that we think may be of interest to you.
We will not share your information for marketing purposes with companies outside our group of companies.
In order to deliver our services to you effectively we may send your details to third parties such as those that we engage for professional compliance, accountancy or legal services as well as product and platform providers that we use to arrange financial products for you.
Where third parties are involved in processing your data we will have a contract in place with them to ensure that the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your data and that they will only act in accordance with our written instructions.
Where it is necessary for your personal data to be forwarded to a third party we will use appropriate security measures to protect your personal data in transit.
To fulfil our obligations in respect of prevention of money-laundering and other financial crime we may send your details to third party agencies for identity verification purposes.
During the course of our relationship with you we will retain personal data which is necessary to provide services to you. We will take all reasonable steps to keep your personal data up to date throughout our relationship.
We are also subject to regulatory requirements to retain your data for specified minimum periods. These are, generally five years for investment business.
These are minimum periods, during which we have a legal obligation to retain your records.
We reserve the right to retain data for longer where we believe it is in our legitimate interests to do so.
You have the right to request deletion of your personal data. We will comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.
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 or write to us using the contact details noted below.
When your personal data is processed by automated means you have the right to ask us to move your personal data to another organisation for their use.
We have an obligation to ensure that your personal information is accurate and up to date. Please ask us to correct or remove any information that you think is incorrect.
We would like to send you information about our products and services and those of other companies in our group which may be of interest to you. If you have agreed to receive marketing information, you may opt out at a later date.
You have a right at any time to stop us from contacting you for marketing purposes or giving your information to other members of the group. If you no longer wish to be contacted for marketing purposes, please contact us by email or post.
For further information visit http://www.allaboutcookies.org/
You can set your browser not to accept cookies and the above website tells you how to remove cookies from your browser. However in a few cases some of our website features may not function as a result.
You also have a right to lodge a complaint with the supervisory authority for data protection. In the UK this is:
Information Commissioner's Office
Or write to us at TCF Fund Managers LLP, 2nd Floor, 107 Cheapside, London, EC2V 6DN.