For the purpose of data protection legislation, the data controllers are
Best International Group Ltd of Moseley Hall Farm, Chelford Road, Knutsford, Cheshire, England, WA16 8RB
Best Asset Management Ltd of Moseley Hall Farm, Chelford Road, Knutsford, Cheshire, England, WA16 8RB for administering investments
Best Distribution Services Ltd of Moseley Hall Farm, Chelford Road, Knutsford, Cheshire, England, WA16 8RB for providing distribution services, marketing, connecting intermediaries, investors (including individuals), to inform of products, and keeping individuals up to date on what is happening in the market.
Best Administration Services Ltd of Moseley Hall Farm, Chelford Road, Knutsford, Cheshire, England, WA16 8RB in relation to the administration services, and information processed through the portal.
If you have any queries, complaints or requests please contact us at email@example.com or 0845 130 9022.
- What information do we collect from you?
- Why do we collect this information?
- How long do we keep hold of your information?
- Who might we share your information with?
- How is your data stored and kept secure?
- What are your rights?
- Changes to this Policy
What information do we collect from you?
We will collect and process the following data about you:
Information you give us. This is information about you that you give us by filling in forms on our sites, when using our service or by corresponding with us by phone, email or otherwise. The information you give us may include your name, address, contact details such as email address and phone number, financial information, demographic information such as preferences and interests, and other information specific to the particular product or service you are interested in which will be brought to your attention at the time of collection of the data.
Information we collect from your use of our sites and portal. With regard to each of your visits to our sites or Best Administration Services or Best Distribution Services portals we will automatically collect the following information:
• technical information, such as the Internet protocol (IP) address used to connect your device to the Internet, whereabouts you connected to our service, your internet service provider (ISP), and what type of device you are using to access our service;
- Information we collect throughout our relationship. This is information relating to the products and services you choose.
- Information we receive from other sources. We are working closely with other organisations, including product providers, agents or IFAs who will provide information about you in relation to our products and services.
- Personal information about other individuals. If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can:
• give consent on his/her behalf to the processing of his/her personal data;
• receive on his/her behalf any data protection notices; and
• give consent to the transfer of his/her personal data abroad.
- Special Categories of information. We may ask you to provide special categories of information. If we request such information, we will explain why we are requesting it and how we intend to use it at the point of collection. Special categories of information includes, amongst other things, your ethnic origin, religious beliefs and physical condition.
Why do we collect this information?
We use this information in the following ways:
Information you give to us. We use this information:
• in order to take steps necessary to assess whether we can enter into a contract with you and in order to perform our contract with you. This includes carrying out our obligations to you
• and providing you with our products and services;
• to administer investment products in accordance with our contracts with product providers;
• for the purpose of improving our service to you and to ensure that content from our sites is presented in the most effective manner for you and for your device;
• to carry out market research, statistical analysis and customer profiling to establish investment interests;
• to deal with any queries relating to your use of our service;
• to issue you with documents relating to your investments or prospective investments;
• to make investments and to make payments to investors;
• to provide you with service communications so that you receive a full and functional service and so we can perform our obligations to you. These may be sent by email or post or, if the circumstances require it, we may contact you by phone. These will include notifications about changes to our service and information about your investments or prospective investments;
• to provide you with marketing communications including, with your permission, information about other goods and services we offer that are similar to those that you have already
• purchased or enquired about;
• to deal with any claims.
Information we collect from your use of the sites or our portals. We will use this information for the following purposes:
• to administer our sites and portal and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve our sites and portal to ensure that content is presented in the most effective manner for you and for your device;
• as part of our efforts to keep our sites and portal safe and secure;
• to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
Information we collect throughout our relationship. We will use this information to help us provide you with our services.
Information we receive from other sources. See the ‘Who might we share your information with?’ section below for details of how we use information in conjunction with our associated third
Monitoring of communication. We may monitor communications with you for the purposes of quality assurance, training and fraud prevention and compliance.
How long do we keep hold of your information?
We will keep information about you for a maximum of 6 years after the end of our relationship with you unless, the law or obligations to our regulators require otherwise or we are required remove such data from our records.
Who might we share your information with?
You agree that for the purposes set out in the ‘Why do we collect this information?’ section above, we have the right to share your personal information with:
Selected associated third parties, some of whom we appoint to provide services, including:
• business partners, subsidiaries, suppliers and sub-contractors for the performance of any contract we enter into with you;
• analytics and search engine providers that assist us in the improvement and optimisation of our sites and portal;
Any member of our group;
Your appointed agent or provider. Additionally, we will disclose your personal information to the relevant third party:
In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
If we are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- To check pre-qualification requirements for investments including financial checks;
- Law enforcement agencies in connection with any investigation to help prevent unlawful activity;
How is your data stored and kept secure?
At Best International Group, we take your safety and security very seriously and we are committed to protecting your personal and financial information. All information kept by us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our service, you are responsible for keeping this password confidential.
We ask you not to share a password with anyone.
We may transfer your data outside the European Economic Area (“EEA”). We will only do so if adequate protection measures are in place in compliance with data protection legislation.
We use Dropbox, which is a US company, as our document management system. Dropbox is signed up to the Privacy Shield certification which aims to ensure the protection and privacy of your data.
From time to time, product providers and investors will be overseas and we may need to pass on your information to enable us to do business. This applies to any special categories of information you give us. If we cannot provide this information to product providers and investors, we cannot provide our services. We will only transfer information outside the EEA if one of the following safeguards is in place:
- transferring to Commission approved countries;
- using Commission approved model contractual clauses;
- requiring companies we transfer data to in countries outside the EEA to be signed up to certification (Such as Privacy Shield in the US).
Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
What are your rights?
Where processing of your personal data is based on consent, you can withdraw that consent at any time.
You have the following rights. You can exercise these rights at any time by contacting us at Moseley Hall Farm, Chelford Road, Knutsford, Cheshire WA16 8RB or firstname.lastname@example.org.
You have the right:
- to ask us not to process your personal data for marketing purposes. We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes;
- to ask us not to process your personal data where it is processed on the basis of legitimate interests provided that there are no compelling reasons for that processing;
- to request from us access to personal information held about you;
- to ask for the information we hold about you to be rectified if it is inaccurate or incomplete;
- to ask for data to be erased provided that the personal data is no longer necessary for the purposes for which it was collected, you withdraw consent (if the legal basis for processing is consent), you exercise your right to object, set out below, and there are no overriding legitimate ground for processing, the data is unlawfully processed, the data needs to be erased to comply with a legal obligation;
- to ask for the processing of that information to be restricted if the accuracy of that data is contested, the processing is unlawful, the personal data is no longer necessary for the purposes for which it was collected or you exercise your right to object (pending verification of whether there are legitimate grounds for processing);
- to ask for data portability if the processing is carried out by automated means and the legal basis for processing is consent or contract.
Should you have any issues, concerns or problems in relation to your data, or wish to notify us of data which is inaccurate, please let us know by contacting us using the contact details above. In the event that you are not satisfied with our processing of your personal data, you have the right to lodge a complaint with the relevant supervisory authority, which is the Information Commissioner’s Office (ICO) in the UK, at any time. The ICO’s contact details are available here: https://ico.org.uk/concerns/