[Policy revised 25th May 2018 and reviewed annually]
Institutional Protection Services Ltd (IP) is a global class and group investor action specialist, providing worldwide shareholder action and settlement monitoring and claims recovery services for institutional investors around the world. IP deals in the management of complex and often data intensive matters. Although, most of the data IP processes is securities and financial related, we do on occasion encounter and process personal data as well. Due to the global nature of its activities IP may transfer certain items of personal data between members of the European Union and non-EEA countries.
IP understands that your privacy is important to you and that you care about how your personal information is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and our obligations under the law.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Account” means an account required to access and/or use certain areas and features of Our Site;
“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 11, below;]
“Our Site” means this website, www.institutionalprotection.com and its publicly facing sub-domains;
“UK and EU Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and]
“We/Us/Our” means Institutional Protection Services Ltd, a limited company registered in England under company number 5247486, whose registered address is 3rd Floor, 1-3 Staple Inn, London WC1V 7QH and whose main trading address is Third Floor, 1-3 Staple Inn, London WC1V 7QH.
2. Information About Us
2.1 Our Site, www.institutionalprotection.com and any sub-domains, is owned and operated by Institutional Protection Services Ltd, a limited company registered in England under Company Number 5247486 whose registered address is 1-3 Staple Inn, London WC1V 7QH. Our VAT number is GB 849324503.
2.2 IP is committed to respecting the privacy of individuals and is registered with the Information Commissioner’s Office in the United Kingdom for data protection purposes.
3. Scope – What Does This Policy Cover?
4. What Data Do We Collect?
4.1 Organisation name
4.3 Email address
4.5 IP address (automatically collected with form submissions)
4.6 Source URL (automatically collected with form submissions)
5. How Do We Use Your Data?
5.1 All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see section 6, below.
5.2 We use your data to provide access to certain areas of Our Site.
5.3 Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
a) you have given consent to the processing of your personal data for one or more specific purposes;
b) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
c) processing is necessary for compliance with a legal obligation to which we are subject;
d) processing is necessary to protect the vital interests of you or of another natural person;
e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
6. How and Where Do We Store Your Data?
6.1 Your data will only be stored in Our Site and used solely for the operation of Our Site and will be automatically deleted after 30 days.
6.2 Your data will only be stored within the United Kingdom.
6.3 Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site.
6.4 Steps We take to secure and protect your data include:
6.4.1 The website uses SSL ensuring your data is not exposed during form submissions.
6.5 Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.
7. Do We Share Your Data?
In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us
8. What Happens If Our Business Changes Hands?
9. Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it.
9.1 You may access certain areas of Our Site without providing any data at all. However, to use authenticated areas available on Our Site you may be required to submit or allow for the collection of certain data.
9.3 You may withdraw your consent for Us to use your personal data as set out in section 4 at any time by contacting Us using the details set out in section 13, and We will delete Your data from Our systems. However, you acknowledge this may limit Our ability to provide you with access to certain areas of Our Site.
10. How Can You Access Your Data?
You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at firstname.lastname@example.org or using the contact details below in section 14.
11. What Cookies Do We Use and What For?
11.1 Cookies are small, plain text files which are downloaded to a device when you access websites. Cookies can be used for a variety of purposes:
- Remembering a user setting or preference, such as a colour or the size of text on a page so that a page can be personalised.
- Remembering information about a feature on a page, such as the fact that you’ve watched a video clip or added an item to a site’s “shopping basket”
- Analysing the website usage, to help the website owners improve the website over time. Cookies cannot be run as a program, or used to give your device a virus. If you would like to find out more about cookies in general, visit: http://www.aboutcookies.org/
11.2 Certain features of Our Site depend on Cookies to function. UK and EU Cookie Law deem these Cookies to be “strictly necessary” as they are “session cookies” and provided purely for security. Your consent will not be sought to place these Cookies. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 11.4, but please be aware that this will block access to parts of Our Site. We have taken great care to ensure that your privacy is not at risk by allowing them.
11.3 You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
11.4 You can choose to delete Cookies at any time however you may lose any information that enables you to access certain areas of Our Site.
11.5 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
12. Summary of Your Rights under GDPR
Under the GDPR, you have:
12.1 the right to request access to, deletion of or correction of, your personal data held by Us;
12.2 the right to complain to a supervisory authority;
12.3 be informed of what data processing is taking place;
12.4 the right to restrict processing;
12.5 the right to data portability;
12.6 object to processing of your personal data;
13. How do we protect your data when it is transferred outside the EEA?
IP complies with the rules in applicable data protection legislation governing the transfer of your personal information from countries in the European Economic Area (EEA) to countries outside the EEA. We may sometimes transfer your personal information to a country outside the EEA but before doing so we will take steps to ensure that your personal information is only transferred in accordance with applicable data protection legislation.
14. Contacting Us