TALON ASSOCIATES LIMITED PRIVACY POLICY 

1. GENERAL 

1.1 Talon Associates Limited is committed to protecting and respecting your privacy. We are the data controller and will process your personal data in accordance with the Data Protection Act 1998 as amended or replaced by the General Data Protection Regulation 2016 and any national laws which relate to the processing of personal data (“data protection legislation”). 

1.2 Please read the following carefully to understand our views and practices regarding Your Data and how we will treat it. 

This policy applies to information we collect about: 

* Visitors to our website 

* Clients 

* Introducers 

* Suppliers 

2. VISITORS TO OUR WEBSITES 

2.1 Types of Data 

Personal Data 

While using our Service, we do not ask you to provide us with personally identifiable information that can be used to contact or identify you ("Personal Data"); but see below regarding email and telephone contact. 

Personally identifiable information may include, but is not limited to: Cookies and Usage Data. 

Usage Data 

We do not collect information how the Service is accessed and used ("Usage Data"). Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. 

Tracking & Cookies Data 

We do not use cookies or similar tracking technologies to track the activity on our Service or hold certain information. 

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyse our Service. 

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. If you do not accept cookies, your experience of this service will not be affected. 

Examples of Cookies: 

* Session Cookies. 

* Preference Cookies. 

* Security Cookies. 

Use of Data 

Talon Associates does not collect your data for use or transfer. 

Service Providers 

We do not employ third party companies or individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analysing how our Service is used. 

2.1.1 While We do not currently collect any data through this service, we may collect and process personal data about you in the following circumstances: 

2.1.2 when, having visited our site, you contact us via email or telephone providing us with your name, address, email address and contact number; 

2.1.3 similarly, whenever you provide information to us when reporting a problem with our Site, making a complaint, making an enquiry or contacting us for any other reason. If you contact us, we may keep a record of that correspondence; 

2.1.4 whenever you disclose your information to us, or we collect information from you in any other way, through our Site. 

2.2 We may use your personal data for our legitimate interests to: 

2.2.1 provide you with information, or services that you requested from us; 

2.2.2 improve our Sites and services; 

2.2.3 process and deal with any complaints or enquiries made by you; and 

Website Links 

Our Site may, from time to time, contain links to and from the websites of third parties that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. Please note that if you follow a link to any of these websites, such websites will apply different terms to the collection and privacy of your personal data and we do not accept any responsibility or liability for these policies. Please check before you submit your information to these websites and we strongly advise you to review the Privacy Policy of every site you visit. 

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services. 

3. CLIENTS 

3.1 We will collect details such as name, address, email address, contact number, date of birth, national insurance number and financial information to provide services to clients. We may also receive details of credit checks undertaken where you have supplied these to us. 3.2 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 

* Three years for mortgage business 

* Indefinitely for pension transfers and opt-out business 

These are minimum periods, during which we have a legal obligation to retain your records. 

We also reserve the right to retain data for longer than this due to the possibility that it may be required to defend a future claim against us. In any case, we will not retain your personal data for longer than 80 years. 

3.3 Children's Privacy; our Service does not normally address anyone under the age of 18. Therefore, where possible, we will avoid collecting personally identifiable information from anyone under the age of 18. If we are required to gather personal data in relation to children under the age of 13 we will obtain parental consent. 

3.4 We will use your personal data provided to comply with our contractual obligations arising from the agreements we enter into with our Clients and share the data with financial institutions who can assist in the provision of financial services to clients including product providers, lenders, banks, insurers, fund managers, platform providers. 3.5 We will use customer personal data for our legitimate interests including: 

3.5.1 With your consent, obtaining your sensitive personal data from third parties including your health, ethnic origin, or criminal prosecutions from third parties such as employers and credit reference agencies, fraud prevention agencies and other similar organisations. 

3.6 We will not transfer any customer personal data outside the European Economic Area (“EEA”). 

4. SUPPLIERS 

We will collect details such as contact names, address, email address and telephone number to contact you about goods and/or services we have ordered from you, to comply with our contractual obligations and to place further orders. We may share your personal data with our employees to manage our relationship with you and we will keep your personal data for as long as we require your goods and/or services subject to a maximum of six years from the date of our last contact with you. We will not transfer your personal data outside the EEA. 

5. LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA 

5.1 In accordance with data protection legislation we are required to notify you of the legal basis upon which we process your personal data. We process your personal data for the following reasons: 

5.1.1 for performance of a contract we enter into with you; 

5.1.2 where necessary for compliance with a legal obligation we are subject to; and 

5.1.3 for our legitimate interests (as described within this policy). 

5.2 We will also process your personal data including personal sensitive data where we have obtained your explicit consent. 

6. DISCLOSURE OF YOUR DATA TO THIRD PARTIES 

6.1 In addition to the third parties mentioned previously in this policy, we may disclose your personal data to third parties for the following legitimate business purposes: 

6.1.1 staff members to facilitate the provision of services to you; 

6.1.2 IT software providers that host our website and store data on our behalf; and 

6.1.3 to a prospective buyer of some or all our business or assets, in which case personal data including Your Data will also be one of the transferred assets. 

6.2 We may disclose your personal data to the police, regulatory bodies, legal advisors or similar third parties where we are under a legal duty to disclose or share your personal data to comply with any legal obligation, or to enforce or apply our agreements; or to protect our rights, property, or safety of our clients, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction. 

6.3 We will not sell or distribute your personal data to other organisations without your approval. 

7. CROSS-BORDER DATA TRANSFERS 

We do not transfer personal data outside the EEA. Where this is required in the future, we will ensure that safeguards are in place so that such transfers comply with data protection legislation. 

8. DATA SECURITY 

8.1 Information you provide to us is shared on our secure servers. We have implemented appropriate physical, technical and organisational measures designed to secure your information against accidental loss and unauthorised access, use, alteration or disclosure. In addition, we limit access to personal data to those employees, agents, contractors and other third parties that have a legitimate business need for such access. 

8.2 Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. 

8.3 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted to our Site; any transmission is at your own risk. 

9. ACCESS TO, UPDATING, DELETING AND RESTRICTING USE OF YOUR DATA 

9.1 It is important that the personal data we hold about you is accurate and current. Please keep us informed if the personal data we hold about you changes. 

9.2 Data protection legislation gives you certain rights in relation to your personal data. You have the right to object to the processing of your personal data in certain circumstances and to withdraw your consent to the processing of your personal data where this has been provided. 

9.3 You can also ask us to undertake the following: 

9.3.1 update or amend your personal data if you feel this is inaccurate; 

9.3.2 remove your personal data from our database entirely; 

9.3.3 send you copies of your personal data in a commonly used format and transfer your information to another entity where you have supplied this to us, and we process this electronically with your consent or where necessary for the performance of a contract; 

9.3.4 restrict the use of your personal data; and 

9.3.5 provide you with access to information held about you and for this to be provided in an intelligible form. 

9.4 We may request specific information from you to help us confirm your identity. Data protection legislation may allow or require us to refuse to provide you with access to some or all the personal data that we hold about you or to comply with any requests made in accordance with your rights referred to above. If we cannot provide you with access to your personal data, or process any other request we receive, we will inform you of the reasons why, subject to any legal or regulatory restrictions. 

9.5 Please send any requests relating to the above to our Data Protection Officer at Talon Associates Limited, 224 Wallace Street, Glasgow, G5 8AE specifying your name and the action you would like us to undertake. Note that in relation to requests to access personal data, we reserve the right to charge a reasonable fee to comply with your request. 

10. RIGHT TO WITHDRAW CONSENT 

Where you have provided your consent to the collection, processing and transfer of your personal data, you may withdraw that consent at any time. This will not affect the lawfulness of data processing based on consent before it is withdrawn. To withdraw your consent please contact us at Talon Associates Limited, 224 Wallace Street, Glasgow, G5 8AE. 

11. CHANGES TO OUR PRIVACY POLICY 

We reserve the right to update this privacy policy at any time, and any changes we make to our privacy policy will be posted on this page. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. 

We will notify you if there are any changes to this policy that materially affect how we collect, store or process your personal data. If we would like to use your previously collected personal data for different purposes than those we notified you about at the time of collection, we will provide you with notice and, where required by law, seek your consent, before using your personal data for a new or unrelated purpose. We may process your personal without your knowledge or consent where required by applicable law or regulation. 

12. CONTACT US 

We have appointed a Data Protection Officer to oversee compliance with this privacy policy. If you have any questions, comments or requests regarding this policy or how we use your personal data please contact our Data Protection Officer at Talon Associates Limited, 224 Wallace Street, Glasgow, G5 8AE. This is in addition to your right to contact the Information Commissioners Office if you are unsatisfied with our response to any issues you raise at https://ico.org.uk/global/contact-us/