Privacy & Cookies

Privacy

TwentyFour Asset Management LLP (“TwentyFour”) respects your right to privacy. This Privacy Notice explains how we collect, share and use personal data about you, and how you can exercise your privacy rights.

If you have any questions or concerns about our use of your personal data, then please contact us using the contact details provided at the bottom of this Privacy Notice.

What personal data does TwentyFour collect and why?

The personal data that we may collect about you generally falls into the following categories:

  • Information that you provide voluntarily
    Certain parts of our website may ask you to provide personal data voluntarily which include your name and contact details (e.g. mailing address, phone number, current and prospect e-mail address), employment details (e.g., your employer, job title), account details (e.g. login names, passwords), and public postings,. We may ask you provide personal data voluntarily when you subscribe for a product or service, subscribe for certain promotional activities, fill out surveys, and correspond with us.

If you contact us, we may keep a record of your correspondence or comments, including personal data, in a file specific to you. We use this information to help us provide better service in the event you contact us again.

We also collect Personally Identifiable Information when you ask that we send products or information directly to other people; in these cases, we will collect the information you submit about the recipient.

  • Information that we obtain from third party sources
    From time to time, we may receive personal information about you from third party sources (including event sponsors, but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us.

When you visit our website, we may collect certain information automatically from your device. In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws.

Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information.  We may also collect information about how your device has interacted with our website, including the pages accessed and links clicked.

Our primary goals in collecting information are to provide customers with superior service and to provide all visitors a smooth, efficient, and personalized experience while using our website. We use this information for our internal analytics purposes and to improve the content of our website and to make our website easier to use.

Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading “Cookies and similar tracking technology” link below

Who does TwentyFour share my personal data with?

We may disclose your personal data to the following categories of recipients:

  • to our group companies, third party services providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our website), or who otherwise process personal data for purposes that are described in this Privacy Notice or notified to you when we collect your personal data;
  • to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
  • to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal data only for the purposes disclosed in this Privacy Notice;
  • to any other person with your consent to the disclosure.

We do not sell, trade, or rent to others the personal data we collect online.

Legal basis for processing personal data

Our legal basis for collecting and using the personal data described above will depend on the personal data concerned and the specific context in which we collect it.

However, we will normally collect personal data from you only (i) where we need the personal data to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so.  In some cases, we may also have a legal obligation to collect personal data from you or may otherwise need the personal data to protect your vital interests or those of another person.

If we ask you to provide personal data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal data is mandatory or not (as well as of the possible consequences if you do not provide your personal data).

If we collect and use your personal data in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our platform and communicating with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our platform or undertaking marketing. We may have other legitimate interests and if appropriate, we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal data, please contact us using the contact details provided under the “How to contact us” heading below.

Your data protection rights

You have the following data protection rights:

  • If you wish to access, correct, update or request deletion of your personal data, you can do so at any time by contacting us using the contact details provided under the “How to contact us” heading below [link].
  • In addition, you can object to processing of your personal data, ask us to restrict processing of your personal data or request portability of your personal data. Again, you can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below [link].
  • You have the right to opt-out of marketing communications we send you at any time. In addition, you can manage your preferences at any time. You can exercise these right by clicking on the “unsubscribe” or “preferences” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “How to contact us” heading below [link].
  • Similarly, if we have collected and process your personal data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.
  • You have the right to complain to a data protection authority about our collection and use of your personal data. For more information, please contact your local data protection authority.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Cookies and similar tracking technology

A “cookie” is a small data file transferred by a Web site to your computer’s hard drive. We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use personal data about you. For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookie Notice here

How does TwentyFour keep my personal data secure?

We use appropriate technical and organisational measures to protect the personal data that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal data.

International data transfers

Your personal data may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country. These countries may have data protection laws that are different to the laws of your country. If service providers in a third country are used, they are obligated to comply with the data protection levels in Europe in addition to written instructions by agreement to the EU standard contractual clauses.

Specifically, our website servers are located in the United Kingdom, and our third party IT service provider and partners operate in the United Kingdom and New Zealand. This means that when we collect your personal data we may process it in any of these countries. The European Commission considers New Zealand to have an adequate level of protection for personal data[1].

However, we have taken appropriate safeguards to require that your personal data will remain protected in accordance with this Privacy Notice.

Data retention

We retain personal data we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business need to process your personal data, we will either delete or anonymise it or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible.

Updates to this Privacy Notice

We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will post those changes here so that you will always know what information we collect online, how we use it, and what rights you have. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make.  We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.

How to contact us

If you have any questions or concerns about our use of your personal data, please contact us at privacy@twentyfouram.com.

The data controller of your personal data is TwentyFour Asset Management LLP, The Monument Building, 11 Monument Street, London EC3R 8AF.

Cookie Notice

A “cookie” is a small data file transferred by a Web site to your computer’s hard drive. We send cookies when you surf our Site, submit a form, or request information. Accepting the cookies used on our Site does not give us access to your Personally Identifiable Information, but we can use the cookies to identify your computer. The aggregate information collected permits us to analyse traffic patterns on our Site. This can enable us over time to provide you with a better experience on our Site by improving the content and making it easier to use.  These cookies allow us to distinguish you from other users of our website, which helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

The cookies we use are “analytical” cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the site when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. You can find more information about the individual analytical cookies we use and the purposes for which we use them in the list below:

Cookies in use as of 15th May 2018 

Browsers

Most browsers accept cookies automatically. You acknowledge that your browser can be set up to notify you about the receipt of cookies. You can withdraw your consent with regard to future use at any time by blocking the receipt of cookies in your browser settings. You can also delete cookies on your computer or mobile device using the feature for doing so in your browser.

To enable or disable cookies in your broswer:

Check which web browser you are using and then select the relevant link below. On the page you are taken to, you will find instructions on how to enable or disable cookies in your web browser.

Google Chrome

Firefox

Internet Explorer

Safari

If you choose not to accept our cookies, you will not be able to see certain information on our websites or use some features that improve your visit.

Parts of our Site may contain links to third-party Web sites for your convenience and information. If you use these links, you will leave the TwentyFour Asset Management Web site. When you access a non TwentyFour Asset Management Web site, please understand that we do not control the content and are not responsible for the privacy practices of that site. We suggest that you carefully review the privacy policies of each site you visit. This Online Privacy Statement does not cover the information practices of those Web sites linked to our Site. These other sites may send their own cookies to users, collect data, or solicit personal information.

You can find out more information on the use of cookies at the following website : www.allaboutcookies.org.

[1] This information is available on the ICO website and European Commission’s data protection website.