1.1         Data protection privacy notice

We are committed to protecting your personal information and ensuring we respect your privacy.  This Privacy Notice explains how we will look after and use any personal information that we collect about you.

1.2         What is personal information?

Personal information means any information about you from which you can be identified.  Examples of personal information include your name, home address, national insurance number, date of birth, telephone number and e-mail address but it also includes other pieces of information which can be used to identify you, either directly or indirectly, such as a cookie.

1.3         Who we are

Praxis Capital Limited is the Controller of the personal information you provide to us.  If you have any questions about this Privacy Notice or the information we hold about you please contact our relevant contact using the details set out below:

Full name of legal entity: Praxis Capital Limited

Name of relevant contact:  David McCann

Email address:  d.mccann@praxis.co.uk

Postal address:  9th Floor, Ship Canal House, 98 King Street, Manchester, M2 4WU

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.  We would however appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

1.4         What types of information do we use?

We sometimes collect personal information in the course of providing our services.  The information which we collect, use, store and transfer may include:

• Employment details (job title, company name, address etc.);
• Contractual/contact information (i.e. our ‘history’ together – services provided or discussed);
• Instructions or requests (for example if you ask for investment advice);
• Financial information (such as financial activity, financial position and history);
• Documentary data (things can include passport or drivers licence or other forms of identification or proof of address);
• Public records (or openly accessible data) such as the Electoral Register;
• Information that is automatically collected via cookies when you visit our website (activity on our website linked to IP address or device ID); and
• Historical information i.e. previous names and addresses
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Our products and services are not intended for children and we will not knowingly collect any data related to children.

We do not collect any special categories of personal data, other than for employees.  This includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic or biometric data.

1.5         Consequences of not providing some types of information

Where we need to collect your personal information by law, or under the terms of a contract we have with you, and you fail to provide that information when requested, we may not be able to provide the goods or services you asked for.  In this case we may have to cancel the product or services but we will tell you if this is the case.

1.6         How do we collect information about you?

Typically we will collect information from you when you contact us directly or provide information in relation to our products and services.  We collect information from and about you through direct interactions when you give us your personal information in written form and /or during correspondence with us, which may include when you meet with us in person or talk to us face to face.

We may also collect data through using our website (when we collect information using cookies or similar technologies which tell us about your equipment, browsing actions and patterns), and through third parties such as credit reference agencies and fraud prevention agencies.  We may also receive personal information from other companies and organisations.

1.7         How we will use your personal information

We only obtain, use and keep personal information where we need it for a specific purpose.  We are only able to use your personal information if we have a proper legal reason or basis for doing so (a “legal basis”) so that your privacy is protected.

Most commonly we will use your information in the following ways:

• Where we have a live business relationship / contract with you.
• We have a legal obligation. We need to use your personal information to comply with laws that assist in the prevention of financial crime and to comply with regulatory obligations.
• We have asked for, and you have provided, consent to use your information.
• We, or a third party, have a legitimate interest in processing the information and your interests and fundamental right do not override those interests. For example, processing your information to prevent fraud.

We set out in the table below all the ways we may use your personal information and the legal bases we rely on to do so.  We also explain what our legitimate interests are where appropriate:

Purpose	Lawful basis for processing including our legitimate interests
To on-board you as a new customer	To fulfil our contact with you To fulfil our legal obligations to prevent financial crime
To manage our relationship with you	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To provide our services on an on-going basis	To fulfil our contract with you
To meet our regulatory obligations in relation to the agreed services provided to you	To fulfil our regulatory obligations
To contact you about other products and services we think you may be interested in	Necessary for our legitimate interests – to develop our products and services and grow our business.
To use data to improve our website	Necessary for our legitimate interests – to understand how our customers interact with our website
To administer our business, including sharing information with our commercial partners	Necessary to ensure we provide an effective service
To report suspected criminal activity to a competent authority	To prevent fraud and other criminal activity
To review and process your CV / employment application if sent to us directly (not through an agency)	Performance of a legitimate request following contact made by applicant

We will only use your personal information for the reason for which we collected it.  We will only use it for another reason if we believe that new reason is compatible with the original purpose.  If we do need to use your personal information for a non-related purpose we will tell you about it and explain the legal basis which allows us to do so.

1.8         Marketing

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Third party marketing

We will get your express opt-in consent before we share your personal data with any other company for marketing purposes.

Cookies

Cookies are small text files placed on your computer (or other device where you access the internet) used to collect information on your activities online. They can also be used as part of website functionality so you should be careful about accepting, deleting or removing them.  We can collect information about the device you are using to access the internet, your IP address and website browser (for example). Cookies can tell us what information you were looking at, for how long, which internet sites interest you which are useful for us particularly for marketing our products and to ensure we are delivering the right service to clients.

For example, we offer investment advisory and asset management services to clients and cookies can tell us how many visitors to the website accessed the information and tools we provide. It may be the information on our website is not clear and we need to improve it – or there may be a genuine need to improve our range of products in the interests of our customers.

If you have concerns about cookies this web site explains how you can delete and control the cookies that are stored on your computer:  https://www.aboutcookies.org/

1.9         Who we share your information with

We may need to provide information to third parties for a variety of reasons, for example, we may need to provide information to assist in the detection or prevention of crime or for the purpose of safeguarding national security.  Please refer to the table in the section ‘How we will use your personal information’ which explains how we use your data.

1.10      Sending your information outside of the United Kingdom

As explained in the section above we will send your information to other third parties who may based outside of the UK, however we will only share your information with them because the following safeguards have been put in place:

• The country we send your information to is deemed to provide an adequate level of protection by the UK, for example it is a country within the EEA;
• The information is being transferred between organisations which are engaged in the same economic enterprise, or within our corporate group, and we have an agreement in place which sets out how your privacy will be protected;
• Or, the entities we transfer your information to are based in the US and are part of the Privacy Shield which requires them to provide a similar level of protection to European standards.

1.11      Storing your information

We comply with UK law, which often requires us to keep certain records – which will include certain personal information – for several years. Our policy is to keep records for up to 10 years after you are no longer a client. We will ensure all records are safely destroyed if we no longer need to retain them.   We review our retention periods for personal information on a regular basis.

When we decide how long we will retain your personal information, we will take into account the amount, nature, sensitivity of your information and how we want to use it as well as the potential risk of harm being caused from unauthorised use or disclosure.

1.12      Your rights

You are provided with a number of different rights under the data protection laws in relation to your personal information.  These allow you:

• To access your information;
• To request we correct your information;
• To request that we erase your information;
• To object to the processing of your information;
• To request a restriction in the processing of your information;
• To request a transfer of your information; and
• To withdraw your consent.

If you wish to exercise any of these rights please contact us  Please note that you will not have to pay a fee to access your personal information or to exercise any of the other rights.  We may, however, charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or we may refuse to deal with your request.  We may also need to seek further information from you to confirm your identity before we release any personal information.  This does not affect your right to make a complaint.

1.13      Security

We have put in place appropriate security measures to protect your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.  We have a procedure to deal with any suspected personal data breach and will notify you, and other regulators, where we are legally required