Dolfin Website Privacy Notice
What is this notice?
Dolfin Financial (UK) Ltd respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. Dolfin Financial (UK) Ltd is the data controller and responsible for your personal data (referred to as “us”, “we” and “our” in this notice).
This privacy notice supplements any other notices we have provided you with on specific occasions in relation to your personal data (for example if you are our client) and is not intended to override them.
What data do we collect about you?
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where a person’s identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
This includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, other technology on the computer or device you use to access this website and, if you are a client logging into the Client Portal available via this website, your log in details.
This is information about how you use our website.
This is the information you give us directly when you communicate with us using any contact details available on this website, sign up to receive further information regarding our services or sign up to receive marketing communications.
How do we use your data?
We will only use your personal data as the law allows us to. The purposes for which we will use your data are as follows.
- To ensure the content from our website is presented in the most efficient manner for you and your computer or device.
- To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). This is necessary to promote our legitimate business interests which in these circumstances are not overridden by your interests and fundamental rights.
- To respond to your communications with us and to send you the information and/or marketing communications you have requested.
Who will we disclose your data to?
We may have to disclose your data to the following third parties for the purposes set out under “How do we use your data”:
- Service providers who provide IT and administrative services.
- Professional advisers and regulatory authorities.
- Other entities in our group.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.
How long will we keep your data for?
We will only store your data for as long as we have a legitimate business interest in doing so (but only where our interests do not override your interests and freedoms). Of course, we will delete your Contact Data from our marketing contacts database as soon as you opt-out of receiving marketing material.
Will we transfer your data outside of the European Economic Area?
Occasionally we may use external third party service providers who are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
How we will keep your information secure?
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
What are your rights?
You have the following rights in relation to how we use your data. If you’d like to exercise these rights please contact us using the contact details listed below under “Who can you speak to at Dolfin about this policy?”.
- Right of access – you have the right to know if we are using your data and, if so, about how we are using it.
- Right of rectification – you have the right to require us to rectify any errors in the information we hold about you.
- Right to erasure – you have the right to require us to delete your data if our continued use of it is not justified.
- Right to restrict processing - in some circumstances you may be entitled to limit the purposes for which we can use your data.
- Right of data portability – you have the right to require us to provide you with a copy of your data in a commonly used machine-readable format or to transfer your data directly to another data controller (e.g. a third party offering services competing with ours).
- Right to object to processing – in some circumstances you may be entitled to require us to stop processing your data.
Who can you speak to at Dolfin about this policy?
Questions, comments and the exercise of your rights regarding this notice and your information are welcomed and should be addressed to the Data Protection Team by email at [email protected] or by post at Dolfin Financial (UK) Limited, 50 Berkeley Street, London, W1J 8HA.
Who is the supervisory authority and how can you contact them?
The Information Commissioner’s Office (“ICO”) is the supervisory authority in the UK responsible for the implementation and enforcement data protection law. You have the right to complain to the ICO about our collection and use of your data.
You can contact the ICO via the ICO website - https://ico.org.uk/concerns/ - or by calling their helpline – 0303 123 1113.
What is this policy?
What are cookies and why do we use them?
Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are useful because they allow a website to recognise a user’s device. You can find more information about cookies at: www.allaboutcookies.org and www.youronlinechoices.eu.
What types of cookies do we use?
We use the following cookies:
- Strictly necessary cookies: These are cookies that are essential for the operation of our website. They allow you to move around and use the features of our website (including accessing its secure areas). Without these cookies, we cannot make our website available to you.
- Analytical/performance cookies: These are cookies which allow us to collect information about how visitors use our website, for instance which areas visitors go to most often, and if they get error messages from particular pages. This helps us to improve the way our website works, for example, by ensuring that visitors are finding what they are looking for easily. Without these cookies, we cannot make improvements that could better your user experience.
- Third party cookies – These are cookies which our website also allows third parties to download to your device. For example, cookies from sharethis.com are used to allow you to send a page from our website to your social media account such as Facebook or Twitter. Cookies from Vimeo are also used. The Vimeo cookie is set on pages that contain Vimeo videos. These third party cookies are not under our control. For further information about their use see www.sharethis.com and www.vimeo.com.
The cookies we use will not collect information that identifies you. The cookies we place on your mobile device will only stay there for the duration of your visit to our website and expire when you close it.
Can you block cookies?
Most mobile devices automatically accept cookies. However, if you prefer, you can change your device settings to prevent automatic acceptance or to notify you each time a cookie is set so that you may accept or reject cookies on a case by case basis. Please note, if you block cookies you may not be able to access all or part of our website.
If you have any questions about this policy please contact the Data Protection Team by email at [email protected] or by post at Dolfin Financial (UK) Limited, 50 Berkeley Street, London, W1J 8HA.