1.General
This privacy policy sets out how Financial Consultants & Management Ltd , trading as Financial Consultants & Management Ltd (" FCM"), use information
about natural people ("Individuals"). This includes:
prospective clients, clients, and their representatives;
website users;
business contacts working with service providers and vendors; and
individuals who agree to participate in market research.
For more information about Financial Consultants & Management Ltd and Financial Consultants & Management Ltd Financial Consulting (together referred to as " Financial Consultants & Management Ltd "), please see
the Regulatory Information section at the bottom of the Financial Consultants & Management Ltd Financial Consulting website.
Financial Consultants & Management Ltd is committed to privacy, and will only use information by which
individuals can be identified ("Personal Data") in accordance with
this policy. This policy applies to Financial Consultants & Management Ltd 's
website and all interactions of Financial Consultants & Management Ltd and/or Financial Consultants & Management Ltd Financial Consulting with UK-based Individuals.
Individuals can contact Financial Consultants & Management Ltd in relation to
this policy using the following details:
Financial Consultants & Management Ltd
Attention: Head of Compliance
Wey House, 15, Church Street, Weybridge, Surrey, KT13 8NA, United Kingdom
info@fcmlimited.com
2. What Personal Data Financial Consultants & Management Ltd Uses
Financial Consultants & Management Ltd and/or Financial Consultants & Management Ltd use the following Personal Data for the following categories of
Individuals:
Prospective clients, clients, and their representatives:
Financial Consultants & Management Ltd uses the name, address and email address
of Individuals provided by third party list vendors to provide
offers for Financial Consultants & Management Ltd 's informational materials. Such
Personal Data may come from public sources and/or such vendor's
private databases.
Financial Consultants & Management Ltd uses the name, address, telephone numbers,
email address, and asset level category of Individuals who provide
such information at the time that they request Financial Consultants & Management Ltd materials, and at the time that they
express an interest in services offered by Financial Consultants & Management Ltd .
When Individuals request that Financial Consultants & Management Ltd provide a
suitability assessment and investment strategy recommendation and/or
engage Financial Consultants & Management Ltd as discretionary investment
manager, Financial Consultants & Management Ltd and/or Financial Consultants & Management Ltd use the Personal Data which Individuals provide directly, including:
Information provided in the Confidential Client Profile;
Information provided in the Confidential Client Agreement, account
statements, account opening documents for Financial Consultants & Management Ltd and/or the custodian and any instruction or mandate form with
respect to Financial Consultants & Management Ltd ' discretionary investment
management service;
Information provided to employee representatives of Financial Consultants & Management Ltd by
telephone, including information Financial Consultants & Management Ltd may request from time to time
to assist in providing services to the Individual.
To conduct a suitability assessment and design a recommended
investment strategy for Individuals, as well as conduct ongoing
suitability assessments for clients, Financial Consultants & Management Ltd uses information provided
by Individuals about their mental and physical health ("Health
Data"), including in the context of conducting a proprietary
assessment of an Individual's life expectancy and any impact on the
investment time horizon for the Individual's assets.
Financial Consultants & Management Ltd is required under the UK Money Laundering,
Terrorist Financing and Transfer of Funds Regulations 2017, the EU
Directive 2015/849 of 20 May 2015 on the prevention of the use of
the financial system for the purposes of money laundering or
terrorist financing ("AML Directive"), and other applicable
anti-money laundering laws and regulations (collectively "AML
Laws"), and Financial Consultants & Management Ltd is contractually required to
support the custodians' obligations under AML Laws, to carry out
identity verification, sanctions checks, and anti-money laundering
and anti-terrorist financing screens. Accordingly, Financial Consultants & Management Ltd uses the
name, date of birth and address provided by Individuals seeking to
become clients of Financial Consultants & Management Ltd to perform a sanctions
and anti-money laundering check using the services of a third party
service provider, which may reveal information relating to criminal
convictions or offences.
Financial Consultants & Management Ltd is required under the Systems and Controls
rules of the UK Financial Conduct Authority ("FCA") and the Markets
in Financial Instruments Directive 2014/65/EU ("MiFID II") to record
telephone conversations that relate to activities in financial
instruments. Accordingly, certain telephone calls between the
Individual and Financial Consultants & Management Ltd will be recorded.
Website users:
Financial Consultants & Management Ltd may place ads on publishers' websites or
within email content, either directly through the publisher or via a
third party. As a result of Individuals interacting with the
advertising content, ad server companies will collect Individuals'
domain types, IP address, and clickstream data.
Financial Consultants & Management Ltd 's website uses cookies and other online
tracking technologies that collect information about internet
browsing habits and history (collectively referred to in this policy
as "cookies"). For more information, please see the cookie policy
below in Section 9.
Business contacts at service providers and vendors:
In dealing with service providers and vendors, Financial Consultants & Management Ltd obtains
information about the business contact, including name, title, name,
address, telephone and fax numbers and email address.
Individuals who agree to participate in market research:
When Individuals agree to participate in market research, Financial Consultants & Management Ltd uses
information about Individuals' marketing, investment and servicing
preferences. Such data is provided directly by Individuals to Financial Consultants & Management Ltd or
to a third party service provider engaged by Financial Consultants & Management Ltd to conduct such
market research.
3. Financial Consultants & Management Ltd 's Use of Personal Data
Financial Consultants & Management Ltd may use Personal Data for the following
purposes, and upon the legal bases set out in the table below.
Purpose for which Financial Consultants & Management Ltd uses Personal Data
Legal Basis upon which Financial Consultants & Management Ltd relies
To assess suitability and design an investment strategy
recommendation
This includes providing financial analysis.
Financial Consultants & Management Ltd can use Personal Data for this purpose because it is necessary
to perform a contract to which the Individual is a party or to take
steps at the request of the Individual prior to entering into a
contract.
Financial Consultants & Management Ltd can also use Health Data for this purpose where Individuals have
consented to it.
To provide discretionary investment management services
Financial Consultants & Management Ltd can use Personal Data for this purpose
because it is necessary to perform a contract to which the
Individual is a party.
In addition, in order to perform a contract to which a
non-Individual client is a party, Financial Consultants & Management Ltd has a
legitimate interest in using Personal Data
(i.e. business contact information, including name, title, telephone
number and email address) of representatives of such party.
To verify identity
Financial Consultants & Management Ltd can use Personal Data for this purpose
where required to comply with AML Laws.
To conduct sanctions and anti-money laundering checks
Financial Consultants & Management Ltd uses name, date of birth and address to conduct sanctions
checks, and anti-money laundering and anti-terrorist financing
screens, which may reveal data concerning criminal convictions or
offences.
Financial Consultants & Management Ltd can use Personal Data for this purpose where required to comply
with AML Laws.
To offer third party products or services
Financial Consultants & Management Ltd can use Personal Data for this purpose
because it is necessary to perform a contract to which the
Individual is a party or to take steps at the request of the
Individual prior to entering into a contract.
To record telephone calls
Financial Consultants & Management Ltd can use Personal Data for this purpose
where required to comply with the FCA rules and MiFID II
requirements.
To carry out direct marketing
This includes sending mail and emails to Individuals on lists rented
from third party list vendors. It also includes following up and
sending promotional material by email, phone or mail to Individuals
who requested informational materials and ongoing insights on
financial matters and investment management services.
Direct marketing is carried out only by Financial Consultants & Management Ltd ;
Financial Consultants & Management Ltd does not carry out marketing in the UK.
Financial Consultants & Management Ltd can use Personal Data for marketing to
Individuals on lists where Individuals have consented to it.
Financial Consultants & Management Ltd can use Personal Data for marketing to
Individuals who requested informational materials and ongoing
insights from Financial Consultants & Management Ltd where Individuals have
consented to it.
In addition, Financial Consultants & Management Ltd can use Personal Data for
marketing to Individuals who previously requested informational
materials from Financial Consultants & Management Ltd because it is in Financial Consultants & Management Ltd Financial Consulting's legitimate interest to promote its business
to such interested Individuals.
This includes contacting representatives (using their business
contact information, including name, title, telephone number and
email address) at non-Individual prospective clients because it is
in Financial Consultants & Management Ltd 's legitimate interest to promote its
business to such non-Individual prospective clients.
To optimise marketing
This includes analysing website visits to Financial Consultants & Management Ltd 's website and the number of clicks through the pages to
request informational materials. It also includes using cookies to
display Financial Consultants & Management Ltd 's online advertisements to
individuals who may be more likely to be interested.
Financial Consultants & Management Ltd does not collect or receive any Personal
Data, including IP addresses, with its cookies. Financial Consultants & Management Ltd can use cookies for this purpose where Individuals have
consented to them.
To conduct market research
This includes conducting market research to ask Individuals about
their marketing, investment and servicing preferences.
Financial Consultants & Management Ltd can use Personal Data for this purpose where Individuals have
consented to it.
To keep records
Financial Consultants & Management Ltd can use Personal Data for this purpose to comply with applicable
financial services laws and regulations (including FCA rules and
MiFID II requirements for Financial Consultants & Management Ltd , and the US
Investments Advisers Act of 1940 and US Securities Exchange
Commission ("SEC") regulations for Financial Consultants & Management Ltd ), the
General Data Protection Regulation ("GDPR") and local laws
implementing GDPR, AML Laws, and other applicable laws and
regulations ("Applicable Law").
In addition, Financial Consultants & Management Ltd can use Personal Data for this purpose beyond the
legally mandated record retention period because it is in Financial Consultants & Management Ltd 's
legitimate interest to keep data for as long as the statute of
limitations so that Financial Consultants & Management Ltd can enforce and defend its legal rights.
To share data with regulators and law enforcement officials
This includes sharing information with the FCA, the SEC, the UK
Information Commissioner's Office ("ICO"), the UK Financial
Ombudsman Service, the UK Financial Intelligence Unit, and other
applicable regulatory and law enforcement bodies, as required.
Financial Consultants & Management Ltd can use Personal Data for this purpose where required to comply
with Applicable Law.
To meet Financial Consultants & Management Ltd 's obligations under regulations and law
This includes reviewing Personal Data as Financial Consultants & Management Ltd and/or Financial Consultants & Management Ltd each carries out its conduct of
business obligations, including monitoring the advice process,
supervising its representatives, and carrying out its compliance
plan.
Financial Consultants & Management Ltd can use Personal Data for this purpose where required to comply
with Applicable Law.
To share data with courts and tribunals
Financial Consultants & Management Ltd can use Personal Data for this purpose because it is in Financial Consultants & Management Ltd 's
legitimate interests to enforce and defend its legal rights.
To train internal staff
Financial Consultants & Management Ltd can use Personal Data for this purpose because it is in Financial Consultants & Management Ltd 's
legitimate interest to train its workforce to offer the best
possible service.
To engage with service providers and vendors
This includes contacting business contacts at service providers and
vendors using their business contact information, including name,
title, telephone number and email address.
Financial Consultants & Management Ltd can use Personal Data for this purpose for its legitimate
interest in engaging with its service providers and vendors.
To suppress Individuals from being contacted
Financial Consultants & Management Ltd can use Personal Data for this purpose
because it is in Financial Consultants & Management Ltd 's legitimate interest to
refrain from contacting Individuals who have requested not to be
contacted or who Financial Consultants & Management Ltd believes should not be
contacted.
Where Financial Consultants & Management Ltd has relied upon its 'legitimate interests' as a legal
basis for a particular purpose, it has performed a 'balancing test'
to ensure that Individuals' rights and interests are taken into
account when their Personal Data is used. Further information on the
balancing test can be obtained by contacting Financial Consultants & Management Ltd 's Data Protection
Officer.
If Individuals fail to provide Personal Data
Where Financial Consultants & Management Ltd needs to collect Personal Data to comply with a legal
obligation, or under the terms of a contract Financial Consultants & Management Ltd has with an
Individual or at the request of an Individual prior to entering a
contract, and the Individual does not provide such data, Financial Consultants & Management Ltd may not
be able to provide services and may need to cancel the contract.
Similarly, if an Individual does not consent to providing Health
Data for the purpose described above, Financial Consultants & Management Ltd may not be able to provide
services and may need to cancel the contract. Financial Consultants & Management Ltd will notify the
Individual if this is the case at the time. If an Individual
requesting informational materials and ongoing insights does not
consent to receiving the same, Financial Consultants & Management Ltd will not be
able to provide such materials and insights.
4. 'Special Category Personal Data' and Data Relating to Criminal
Convictions
"Special Category Personal Data" includes data which reveals racial
or ethnic origin, political opinions, religious or philosophical
beliefs, or trade union membership. It also includes genetic data,
biometric data for the purpose of uniquely identifying an
Individual, data concerning health or data concerning an
Individual's sex life or sexual orientation.
As noted above, Financial Consultants & Management Ltd collects and uses Health Data to assess
suitability with consent of the Individual. In addition, Financial Consultants & Management Ltd conducts sanctions and anti-money laundering checks to comply with
AML Laws, which may reveal data concerning criminal convictions or
offences. The collection or use of any other types of Special
Category Personal Data will only be with consent of the Individual.
5. Financial Consultants & Management Ltd 's Sharing of Personal Data
Who will Financial Consultants & Management Ltd share data with?
Financial Consultants & Management Ltd will not sell or lease Individuals' Personal Data to third
parties.
For the purposes listed in section 3 above, Financial Consultants & Management Ltd may share Personal Data
with:
Financial Consultants & Management Ltd will share information , which is its parent company. Financial Consultants & Management Ltd acts as a service provider of marketing, human resources, finance,
information technology and legal support services to Financial Consultants & Management Ltd , and also serves as a discretionary investment manager
to Individuals in the UK after being introduced by Financial Consultants & Management Ltd . In these capacities, all data collected and used by Financial Consultants & Management Ltd Financial Consulting will be accessible by Financial Consultants & Management Ltd . Financial Consultants & Management Ltd is located in the United
States; accordingly, Financial Consultants & Management Ltd has put in place
safeguards in the form of Model Clauses with Financial Consultants & Management Ltd as described below.
Financial Consultants & Management Ltd -authorised vendors, service providers, agents and
representatives. These organisations are as follows:
Custodians that hold custody of Individuals' assets managed by Financial Consultants & Management Ltd Financial Consulting, as well as custodians, brokers and dealers
that execute trade order instructions for Individual clients of Financial Consultants & Management Ltd Financial Consulting. The custodians holding Individuals' assets
will also have a direct contractual relationship with the
Individuals whose assets they hold. Such custodians are generally
located in the UK and are subject to applicable Financial Services
Laws. If an Individual requests an account held by a custodian
located in the United States, Financial Consultants & Management Ltd will
transfer Personal Data in connection with such account only with
consent of the Individual.
Self Invested Pension Plan ("SIPP") providers in the UK that provide
SIPPs to clients of Financial Consultants & Management Ltd and that are subject
to applicable Financial Services Laws.
Regulatory DataCorp, Inc. ("RDC") and Tracesmart Ltd. ("TraceSmart"),
which carry out the sanctions and anti-money laundering checks on
behalf of Financial Consultants & Management Ltd as described above in section 3. RDC is located in the
United States; accordingly, Financial Consultants & Management Ltd has put in place safeguards in the
form of Model Clauses with RDC as described below. TraceSmart is
based in the UK.
Information technology security providers, such as internet firewall
and malware detection providers. Such providers are generally
located in the United States; accordingly, Financial Consultants & Management Ltd has ensured such providers have safeguards in the form of Model
Clauses as described below or are Privacy Shield certified.
Direct marketing agents and service providers, including website
host companies that collect Personal Data on behalf of Financial Consultants & Management Ltd from Individuals interested in Financial Consultants & Management Ltd 's informational materials, calling service providers
that follow up with Individuals who have expressed an interest in
Financial Consultants & Management Ltd 's informational materials, merge-purge
service providers that ensure mailing lists are accurate, and
mailing service providers that send mail to Individuals on behalf of
Financial Consultants & Management Ltd . Such agents and service providers may be
located either within or outside the EEA; Financial Consultants & Management Ltd has put in place safeguards in the form of Model Clauses with those
located outside the EEA as described below.
Providers of third party professional advice, such as lawyers and
auditors.
Regulators (such as the FCA, SEC and ICO) and law enforcement
organisations, as described above in section 3.
If Financial Consultants & Management Ltd and/or Financial Consultants & Management Ltd sells,
transfers or merges part or all of its business, or attempts to do
so, then third parties may receive Personal Data.
What safeguards are in place where data is transferred outside of
the EEA?
Where data is transferred by Financial Consultants & Management Ltd to Financial Consultants & Management Ltd Financial Consulting, Individuals' data will be transferred to the
United States, where the laws do not provide the same level of data
protection as the country in which the Individual initially provided
the data. Financial Consultants & Management Ltd will therefore make the transfer
in accordance with the European Commission Standard Contractual
Clauses ("Model Clauses"). The European Commission has determined
that the Model Clauses offer sufficient safeguards to protect
Individuals' privacy and their fundamental rights and freedoms,
including the ability to exercise their rights. For more information
on EU Standard Data Protection Clauses please visit https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.
Furthermore, as described above, some of the third party service
providers that process Personal Data on behalf of Financial Consultants & Management Ltd are located in
countries outside the EEA that have not been recognised by the
European Commission as providing an adequate level of data
protection. In these cases, Financial Consultants & Management Ltd has put in place measures to ensure
that Individuals' Personal Data is adequately protected, including
by having the third party service provider entering into Model
Clauses or by ensuring that the third party service provider is
certified to the EU-US Privacy Shield. Please contact Financial Consultants & Management Ltd using the
contact details in section 1 above with any questions about the
safeguards in place to protect Personal Data when transferred
outside the EEA (including how to obtain a copy or consult these
safeguards).
6. Consent
In accordance with applicable data protection laws, Individuals who
consent to Financial Consultants & Management Ltd using their Personal Data may contact Financial Consultants & Management Ltd at any time
to say that they withdraw that consent, and that they do not want
their Personal Data to be used for those purposes. Individuals may
do so by contacting Financial Consultants & Management Ltd using the details set out in section 1
above.
When doing so, Individuals should:
ensure that a full name and address and/or email address is provided
in exactly the form in which it was originally provided to Financial Consultants & Management Ltd to
avoid any possible confusion with a different Individual; and ensure
that the particular uses for which consent is being withdrawn are
specified. The uses for which Financial Consultants & Management Ltd relies on consent are set out in
section 3 above. Individuals may also unsubscribe from direct email
marketing via Financial Consultants & Management Ltd 's online form at https://www.finconsultmanagement.com/unsubscribe.
7. Individuals' Rights
In accordance with applicable data protection laws, Individuals may
exercise rights in relation to the Personal Data that Financial Consultants & Management Ltd holds
about them.
An Individual's rights under applicable law may include access to
the Personal Data that Financial Consultants & Management Ltd processes about the Individual, the right
to have such Personal Data corrected or erased, the right to
restrict the processing of the Individual's Personal Data, as well
as the right to data portability. Where Financial Consultants & Management Ltd has obtained an
Individual's consent for the processing of Personal Data, the
Individual has the right to withdraw consent at any time. This will
not affect the lawfulness of the processing that has happened based
on consent prior to the withdrawal. An Individual also has the right
to object, at any time, to the processing of Personal Data which is
based on Financial Consultants & Management Ltd 's legitimate interests. Where Financial Consultants & Management Ltd processes Personal Data for direct marketing purposes, an Individual
has the right to object at any time to such processing, including
for profiling purposes to the extent that it is related to direct
marketing. If an Individual objects to processing for direct
marketing purposes, Financial Consultants & Management Ltd will no longer process
the Individual's Personal Data for such purposes.
To exercise these rights, Individuals should contact Financial Consultants & Management Ltd using the
contact details set out in section 1 above. In each case,
Individuals should ensure that the full name and address and/or
email address are provided in exactly the form in which they were
originally provided to Financial Consultants & Management Ltd to avoid any possible confusion with a
different Individual. If Individuals are not satisfied with the way
Financial Consultants & Management Ltd handles the request, they may lodge a complaint with the
supervisory authority in their country of residence.
8. Security
Financial Consultants & Management Ltd is committed to ensuring that Personal Data is secure. In order
to prevent unauthorised access or disclosure, Financial Consultants & Management Ltd has put in place
suitable physical, electronic and managerial procedures to safeguard
and secure Personal Data collected. Financial Consultants & Management Ltd uses encryption when
collecting or transferring sensitive data.
9. Cookies
For further information on cookies and how to manage them, please
click here.
A cookie is a small text file with an identification tag that is
created and downloaded to a user's computer (or other device) when
accessing websites that use cookies. Cookies allow a website to,
among other things, store and retrieve information about a user's
online activity, browsing habits of a user or user's computer (or
other device) and, depending on the information they contain and the
way a user uses a computer (or other device), may be used to
recognise the user.
Cookies can be categorised by who places them:
First-party cookies: These cookies are downloaded to a user's
computer (or other device) from a computer or domain managed by the
publisher of the website whose service the user is requesting.
Third-party cookies: These cookies are downloaded to a user's
computer (or other device) from a server or domain that is not
managed by the publisher of the website, but by another entity that
may be seeking data obtained through cookies.
Cookies can also be categorised by their duration:
Session cookies: These cookies are designed to collect and store
data while the user accesses a website. They are often used to store
information for the duration of a visit to the website (e.g. what
account user is logged into). Once a user leaves the website, the
session cookie is deleted.
Persistent cookies: These cookies store data on the user's computer
(or other device) for the duration period set within the cookie's
file, which is determined by the entity controlling the cookie and
can range from a few minutes to several years, or until the user
manually deletes them.
Lastly, cookies can be categorised by the function they serve. Financial Consultants & Management Ltd Financial Consulting uses the following types of first- and
third-party cookies:
1. Functionality Cookies
Financial Consultants & Management Ltd uses functionality cookies to keep track
of whether or not a user has consented to have other types of
cookies placed on their computer (or other device) and, if the user
has consented, to note when consent was obtained. Functionality
cookies do not collect any Personal Data. Enabling functionality
cookies may be necessary to access the full content of website
material.
2. Personalisation Cookies
Personalisation cookies allow the website to remember information
that changes the page's appearance or behaviour, such as, for
example, the language selected for viewing the page.
3. Analytics Cookies
Analytics cookies analyse site statistics and how users browse the
Financial Consultants & Management Ltd websites and enable Financial Consultants & Management Ltd to measure the number of visitors to the website, as
well as to measure and analyse how users interact with the website.
This information is used to improve Financial Consultants & Management Ltd 's
websites and the products or services offered.
4. Behavioural Cookies
Financial Consultants & Management Ltd serves advertisements on various websites
using third-party companies. If a user visits a Financial Consultants & Management Ltd website or clicks on one of Financial Consultants & Management Ltd 's
advertisements, behavioural cookies will be placed on the user's
computer (or other device). Behavioural cookies allow Financial Consultants & Management Ltd to manage and optimise its digital marketing (e.g.
banner ads, pages offering informational brochures, email campaigns,
etc.). Behavioural cookies may be used to build a user profile to
provide users with content more relevant to their interests. They
adapt advertising and the content users see on other websites based
on their browsing habits, including how users navigate the Financial Consultants & Management Ltd Financial Consulting websites and other websites that the user may
visit, as well as how users interact with internet advertising.
Financial Consultants & Management Ltd uses the third party personalisation,
analytics and behavioural cookie services provided by the companies
below and these companies may have access to information collected
by the cookies. More information about these cookies can be found at
here.
10. How to Manage Cookies
A user can manage cookie preferences for the Financial Consultants & Management Ltd website by using Financial Consultants & Management Ltd 's online
cookie preference tool at Privacy Options.
Some browsers have a "Do Not Track" setting that allows users to
send a signal to the websites they visit that the user does not wish
to be tracked. Financial Consultants & Management Ltd 's website may not respond
to these signals.
11. How Long Financial Consultants & Management Ltd will keep Data for
Information of Individuals that are clients of Financial Consultants & Management Ltd (meaning any
Individual who has received an investment strategy recommendation or
has retained Financial Consultants & Management Ltd as discretionary investment manager) will be kept
for the duration of the client relationship plus ten years in order
for Financial Consultants & Management Ltd to satisfy its recordkeeping obligations under applicable
Financial Services Laws, as well as to enforce or defend its legal
rights. However, information relating to pension transfers will be
kept indefinitely as required by applicable Financial Services Laws.
Information on identity verification and sanctions and anti-money
laundering checks will be kept for the duration of the client
relationship plus five years in order for Financial Consultants & Management Ltd to satisfy its recordkeeping obligations under applicable AML Laws.
Recordings of telephone calls will be retained for a period of five
years in order for Financial Consultants & Management Ltd to satisfy its
recordkeeping obligations under applicable Financial Services Laws.
Information of Individuals will be kept for a period of five years
from the date the Individual consented to direct marketing or until
the Individual requests earlier erasure of their information.
However, where an Individual consents to have their information
retained by the Company to receive ongoing information and insights
(subscription) from the Company, their information will be kept
until they opt out unless they did not receive a regular opportunity
to opt out in which case such information will be retained for five
years from consent. In some cases, such general retention periods
may be extended for up to ten years for some Individuals who are in
more advanced discussions with Financial Consultants & Management Ltd or have had
regular interactions or meetings with Financial Consultants & Management Ltd about its investment management services, unless the Individual
requests earlier erasure of their information. Information collected
for the purposes of conducting market research will be kept for up
to two years following such research, unless the Individual requests
earlier erasure of their information. Contact information for
vendors/service providers and contact information for Individuals on
suppression lists (i.e. name, address, email address and/or phone
number) will be retained indefinitely.
12. Questions and Complaints
If Individuals have any questions or complaints in relation to Financial Consultants & Management Ltd 's
data protection practices, Financial Consultants & Management Ltd encourages Individuals to get in
contact using the contact details set out in section 1 above.
Individuals also have the right to lodge a complaint with a data
protection authority where they believe that Financial Consultants & Management Ltd has infringed data
protection rules. In particular, this complaint can be made to the
data protection authority in the country in which that Individual
usually lives, usually works, or the country where the Individual
believes the infringement took place.
13. Changes to Privacy & Cookie Policy
From time to time, Financial Consultants & Management Ltd may use Personal Data for new, unanticipated
uses not previously disclosed in this policy to the extent permitted
by law. If its practices regarding Personal Data change at some time
in the future, Financial Consultants & Management Ltd will post the policy changes to https://fcmlimited.com and notify Individuals of these changes and provide the ability to
"opt out" or unsubscribe from these new uses.