Privacy Policy & GDPR

24Haymarket Limited, its subsidiaries and associated businesses (‘24Haymarket’ and ‘we’) are committed to protecting your personal data and your privacy.  We endeavour to ensure that any personal data we collect about you will be held and processed strictly in accordance with the Data Protection Act 2018 (DPA) and the European General Data Protection Regulation (GDPR). The terms Personal Data, Data Controller and processing have the meanings given to them in the GDPR unless otherwise indicated.

Article 5 of the GDPR states that Personal Data must be processed lawfully, fairly and in a transparent manner. This privacy policy is for this website and governs the privacy of its users, who choose to use it. It explains how we comply with the GDPR, the DPA and the Privacy and Electronic Communications Regulations (PECR).

At 24Haymarket Limited, we collect and process Personal Data in a number of ways. For instance, please see the below:

  • You are browsing our website, inquiring about our services; receiving our marketing communications, responding to one of our surveys or otherwise interacting with us as a prospective, current or former investor other than in connection with ongoing services we are providing to you or your organisation;
  • You are a client of 24Haymarket Limited;
  • You are applying for or inquiring about a job at 24Haymarket Limited
  • You are an employee or contractor of 24Haymarket Limited
  • You are a supplier or service provider to 24Haymarket Limited

1. Scope

This Privacy Policy demonstrates how 24Haymarket handles the Personal Data you provide to us, or which we collect on you, in the following ways (Your Data):

  • by you submitting information to us through our website http://24haymarket.com/ (Website User Data);
  • through your use of our other marketing resources, such as events or webinars which we run or sponsor (Marketing Data);
  • from what we learn about you from your visit to our websites (Website Background Data); and/or
  • by you otherwise interacting with us a prospective, current or former investor, (for example, where you provide your business card to us) other than in connection with ongoing services we are providing to you or your organisation (Prospect Data).

This statement does not apply to:

  • the collection and processing of Personal Data while providing investment services or other services to our clients. For information about privacy in the context of services provided to our clients, please contact 24Haymarket.
  • the collection and processing of Personal Data about our employees or contractors. For information about privacy in the context of doing work for 24Haymarket please contact us.
  • the collection and processing of Personal Data in relation to job candidates or applications for roles advertised on this website. For information about privacy in this context, please contact us separately.
  • the collection and processing of Personal Data on our suppliers or service providers. For information about privacy in this context, please contact us separately.

This website is not intended for children and we do not knowingly collect data relating to children.

We do not collect any Special Categories of Personal Data about you (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 and biometric data). Nor do we collect any information about criminal convictions and offences.

 

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

 

2. Identity and Contact Details of Data Controller

For the purposes of the DPA and the GDPR, 24Haymarket Limited is the controller of Your Data.  If you have any queries regarding this policy or complaints about our use of Your Data, please contact us at contact@24haymarket.com and we will do our best to deal with your complaint or query as soon as possible.

24Haymarket Limited
3rd Floor, 24Haymarket
London SW1Y 4DG

FAO: Data Processing

 

3. What we use Your Data for

The table below sets out the purposes for which we may process Your Data and the legal basis for the processing:

Data Purpose Legal Basis
  • Website User Data
  • Marketing Data
  • Prospect Data
To keep you informed of any activities undertaken by us which we believe may be of interest to you and this use may include sending you email and postal marketing from time to time or requests to respond to a survey  

Legitimate interest of 24Haymarket Limited. We send you emails with regards to our activities. Before doing so we would ensure that we have weighed your interests and risk posed to you against our own and that such interests are proportionate and appropriate such as for the purposes of marketing.

 

  • Website User Data
  • Website Background Data
Website analytic purposes.  For further details on the technology we use to analyse our website’s performance, please see our cookies policy below.  

Consent – this will be obtained when you click on the banner at the top of our website to accept certain cookies.

Legitimate interest of 24Haymarket Limited (see our cookies policy for further information)

  • Website User Data
  • Marketing Data
  • Prospect Data
To provide you with the newsletter(s) or information you have requested Performance of a contract
  • Website User Data
  • Marketing Data
  • Prospect Data
  • Website Background Data
  • Prospect Data
  • Survey Data
To respond to requests for information from regulated bodies or government agencies Compliance with a legal obligation
  • Website User Data
  • Prospect Data
To respond to an enquiry, you have submitted  

Legitimate interest of 24Haymarket Limited – it may be necessary for us to process Your Data to reply or respond to your enquiry

 

4. Who we share Your Data with

Please note that we may on occasion be required to share your information with the following categories of recipients:

  • Third parties who provide services on our behalf. For example, we use third parties such as MailChimp or others to provide marketing automation services. A full list of all our third-party service providers is available on request.
  • Your information may be sent to, and we may use information from, credit reference agencies and fraud prevention agencies. We may need to send your information to external parties if we are legally required or are permitted by law or regulation to do so. This could be as a result of, for example, a contractual obligation, a court order, a regulatory requirement (e.g. Financial Conduct Authority) or a request from another body or organisation such as the police, the Department of Work and Pensions or Her Majesty’s Revenue and Customs.
  • We use external outsourcers for a variety of purposes, e.g. to carry out administration on our behalf or to provide support services. As a result, your information may need to be passed to them. This will change from time to time but currently includes by way of example administration services, document storage or retention and providers of IT services. In each case a contract will be put in place with these outsourcers or service providers with obligations about the use and security of your information.
  • Our professional advisors, such as lawyers, accountants, regulated service providers, to the extent they may be engaged to provide specific services to us as part of our business and operations.
  • Other entities within our corporate group, such as subsidiary companies.
  • In certain circumstances we may transfer your personal information overseas to countries that may not provide the same level of data protection as the UK. This is most likely to happen in the case of administration outsourcing. If we do this, appropriate steps will be taken to ensure that your information is protected.

We have taken steps to ensure that all such entities keep Your Data confidential and secure and only use it for the purposes that we have specified and have informed you of.  Our service providers are subject to data processing agreements which are compliant with the requirements set out in the GDPR.  Further details regarding any third parties who are located outside the EEA are set out in paragraph 5 below.

In relation to any other third parties, we will only disclose your information in the following circumstances:

  • where you have given your consent;
  • where we are required to do so by law or enforceable request by a regulatory body;
  • where it is necessary for, or in connection with legal proceedings or in order to exercise or defend legal rights; and
  • if we sell our company, go out of business, or merge with another company.

 

5. International Transfers

In certain circumstances, we may transfer Your Data to countries outside the EEA, which may not adhere to the same levels of data protection to which countries within the EEA are subject.  Any such transfers are always made in accordance with the DPA and the GDPR.  Details of the circumstances and mechanisms in place to ensure compliance are set out below:

Google Analytics: We use Google Analytics to obtain information on website statistics. Google, (including Google LLC and its wholly owned US subsidiaries) participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. Google Analytics terms prohibits the collection of any personally identifiable information. Analytics data is transmitted over HTTPS. Reports are only available to authorised Google accounts. Transfers of Personal Data to Google in the United States are therefore made subject to appropriate safeguards in accordance with the DPA and the GDPR. Google’s privacy policy can be viewed here.

MailChimp: We use MailChimp to provide marketing automation services in relation to our subscribers. If you subscribed through our website or have consented to 24Haymarket using Your Data to send you marketing communications, Your Data may be transferred to MailChimp’s servers in the United States.  The company that operates MailChimp, The Rocket Science Group LLC, participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. Transfers of Personal Data to MailChimp in the United States are therefore made subject to appropriate safeguards in accordance with the DPA and the GDPR. MailChimp’s privacy policy can be viewed here.

 

6. Retention Period

Your Data will be stored for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements, which is generally for a maximum period of 6 years, after which time it will be destroyed if it is no longer required for the lawful purpose(s) for which it was obtained. If you consent to marketing, any information we use for this purpose will be kept with us until you notify us that you no longer wish to receive this information, unless we request your consent to store it for a longer period.

 

7. Your Rights in relation to Your Data

Under the GDPR, you will have the following rights in relation to how we process Your Data:

  • Right to request access – you may obtain confirmation from us as to whether Your Data is being processed and, where that is the case, access to Your Data.
  • Right to rectification and erasure – you have the right to obtain rectification of inaccurate personal data we hold concerning you and to obtain the erasure of Your Data without undue delay in certain circumstances.
  • Right to the restriction of processing or to object to processing – you may require us to restrict the processing we carry out on Your Data in certain circumstances or to object to us processing Your Data.
  • Right to data portability – you have the right to receive Your Data in a structured, commonly used and machine-readable format.
  • Right to withdraw consent – where you have provided your consent to us processing Your Data, you have the right to withdraw your consent at any time. This can be done by emailing contact@24haymarket.com any time or by clicking the “unsubscribe” link on any marketing communications you receive from us.
  • Right to lodge a complaint – you may lodge a complaint with any supervisory authority in the EU. The supervisory authority for the United Kingdom is the Information Commissioner’s Office. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

For further information on your rights, please see the Information Commissioner’s website here.

If you wish to exercise any of the rights set out above, please contact us.

 

8. Additional Information

  • There is no statutory or contractual requirement for you to provide Your Data to us and you are not obliged to do so. Please note, however, that we may not be able to provide you with the services you have requested, such as to receive our newsletter and or blog if you do not provide your contact details.  As set out in our cookies policy, our website may not be able to function fully if you do not agree to certain cookies being set on your computer.
  • We do not undertake automated decision-making or profiling on Your Data.
  • We keep our privacy policy under constant review and may change it from time to time to reflect our practices or to remain compliant with relevant legislation. We will notify you of any material changes to our privacy policy via a notification on our website. Your continued use of this website or our other marketing services, following the posting of changes to these terms, will mean you accept these changes.
  • It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

 

9. Security of personal information

We recognise the need to ensure that personal information gathered via this website remains secure. Our storage of data has security measures in place to protect against the loss, misuse and alteration of the personal information under our control. Our security measures include encryption to prevent unauthorised access. You acknowledge that although we exercise adequate care and security there remains a risk that information transmitted over the Internet and stored may be intercepted or accessed by an unauthorised third party.

 

10. Data obtained indirectly

In some circumstances, we may obtain Personal Data about you from other sources.  This information may include your name, contact details and job title, which we obtain from third-party sources such as industry market research providers, organisers of events we sponsor or other publicly available sources, such as your company’s website.

 

11. Links

Our website contains links to other websites belonging to third parties. We do not control the privacy practices of these other websites. You should, therefore, make sure when you leave our website that you have read that website’s privacy policy.

 

Website Disclaimer

The information and data contained in this site (“the Information”) is not intended to be published or made available to any person in any jurisdiction where doing so would result in contravention of any applicable laws or regulations. Accordingly, if it is prohibited to make such information available in your jurisdiction or to you (by reason of your nationality, residence or otherwise) it is not directed at you. Before reviewing the pages of our site, you must be satisfied that doing so will not result in such a contravention and is not so prohibited, and by proceeding to review them you will be confirming that this is not the case.

24Haymarket has taken all reasonable care and precaution to ensure that the Information is fair and accurate or has been compiled from sources believed to be reliable. Nevertheless, we do not make any representations or warranty, express or implied, as to the accuracy, completeness, or fitness for any purpose or use of the Information. The Information may not in all cases be current and it is subject to continuous change. Accordingly, you should not rely on any of the Information as authoritative or a substitute for the exercise of your own skill and judgement in making any investment or other decision. We do not warrant that the supply of Information will be uninterrupted or error free and we shall not be liable for any direct, indirect, or consequential loss arising from any use of or reliance on the Information from this site.

The Information does not constitute or form part of an offer, subscription, recommendation or solicitation to buy or sell any securities, futures or options on futures or to take up any services, nor shall it be relied on in connection with any contract or commitment whatsoever.

All content of the site is provided for information purposes only. You agree that the Information should not be interpreted as investment advice or as an offer to buy or sell any security or futures contract. WE ARE NOT A REGISTERED BROKER-DEALER OR FINANCIAL ADVISOR. WE DO NOT PROVIDE PERSONAL INVESTMENT ADVICE. Remarks and data comprising the site are for information purposes only and are provided without warranty of any kind. In no event will we be liable for any direct, indirect, consequential, or accidental damages arising out of any decision made or action taken by you in reliance on the Information or any part of this site, whether or not caused in whole or part by our negligence. The content is strictly intended for Professional Investors only.

You must not distribute any of the Information to any other person without attaching a copy of this page and obtaining the agreement of such other person to comply with the terms set forth in this disclaimer notice. If you distribute any of the Information without attaching a copy of this disclaimer notice or obtaining the agreement of its recipient to comply with the terms set forth you will be liable to indemnify against www.frankinvestments.co.uk any costs or other losses arising from any complaint, claims or actions arising directly or indirectly from such distribution.

Any person is hereby authorised to view this document or to create a link to this document for informational purposes only. No part of this document may be redistributed, copied or reproduced without prior written consent of 24Haymarket Limited.

Indemnification: A visitor to this site agrees to defend, indemnify and hold 24Haymarket Limited, its employees and other representatives, harmless from and against all liabilities, damages, claims, actions, costs, expenses (including lawyer’s fees), in connection with or arising from the visitor’s use or misuse of this site.

 

Risk Disclaimer

This website does NOT give any recommendation to buy or sell any securities or to make any investments. Anyone wishing to invest or speculate in the securities market should seek their own financial or professional advice.

 

Linked Sites

24Haymarket Limited does not take any responsibility for the content of off-site pages or any other websites linked or linking to the website.

 

COOKIE POLICY

The 24Haymarket website, like many websites, uses cookies to run the content management system and to collect anonymous visitor data. In keeping with recent legislation, we are making users more aware of these cookies and providing links to help visitors decline or remove cookies.

What are cookies?

A cookie is a small file of letters and numbers put on your computer as part of your use of a website. More details about cookies are available from several online sources including All About Cookies.

Why do we use cookies?

Cookies are integral to modern websites. They allow us to distinguish visitors from each other and (anonymously) record the traffic to the website. This helps ensure a good user experience, and the data is valuable in assessing and improving the website.

Which cookies do we use?

We use the following cookies on this site:

Google Analytics cookies. We employ: utma, utmb, utmz, and utmc. These are performance cookies. We collect them anonymously and assessing the data they provide allows the site to be improved. Google provides details of all the cookies used by Google Analytics. By using the website, you agree that we can place these types of cookies on your device.

Opting out, removing and managing cookies

If you are uncomfortable with the use of cookies, most browsers now permit users to opt-out/block them. This varies from browser to browser – please see ‘Managing cookies’ below. However, if you choose to opt-out/block cookies you may not be able to access certain sections of the site, and/or functionality may be impaired. Alternatively, you may wish to delete the cookies from your system/computer at the end of your visit to our site.

Managing cookies

You can change your browser settings to manage cookies – including opting-out/blocking. The website About Cookies gives browser-specific instructions on how to manage cookies. If you would like to prevent all Google Analytics cookies being set, you may want to install the Google Analytics Opt-Out Browser Add-On. Please note that opting-out or blocking cookies may impair your use of this (and other) websites.

 

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