Terms & Conditions
Your attention is particularly drawn to the provisions of clause 6 (Our responsibility to you - limitation of liability)
1.1 These terms and conditions govern your use of or attendance to:
1.1.1 www.environmental-finance.com, www.insuranceerm.com, www.insuranceassetrisk.com, www.insuranceriskdata.com, www.fieldgibsonmedia.com and www.bonddata.org (Websites);
1.1.2 the magazines published by Field Gibson Media, including those for Environmental Finance, Insurance Asset Risk and InsuranceERM (Magazine);
1.1.3 the content available on or in the above (Content); and
1.1.4 any event organised by Field Gibson Media (Event).
1.2 By using our Websites, Magazine, accessing any Content or attending any Event you accept these terms of service on behalf of yourself and, if you are doing so in the course of your work or business, on behalf of that business. If you disagree with any part of these terms and conditions, or are not authorised to accept them on behalf of your business or work, please do not use the Websites, Magazine or Content and / or do not attend any of our Events.
1.3 These terms and conditions were last updated on 05 January 2021 and replace all previous Field Gibson Media terms and conditions. We reserve the right to update these terms and conditions as necessary for legal or regulatory reasons or in order to reflect any changes made to our services. If you are a subscriber or you have registered with us for an Event, we will send you an email to notify you of any such changes. We will also post the changes on this page and we recommend that, if you use any of our services, you check this page from time to time.
1.4 The Websites are owned and operated by Field Gibson Media Limited (Field Gibson Media), a company incorporated in England and Wales with company number 02516864, registered address at Pentagon House, 52-54 Southwark Street, London, England, SE1 1UN. Field Gibson Media has the VAT number 947181208 and Data Protection Registration number ZA098022..
2. Access and use of the websites
2.1 Unless otherwise stated, all intellectual property rights (including copyright and database rights) in the Content and any part of it are owned by Field Gibson Media or its licensors.
2.2 You may view Content for your individual use on any device compatible with the Websites. You may download and store Content from the Websites for your individual use and may print (though not photocopy) single copies of articles for your individual use.
2.3 You may not use the Websites or Content for any unlawful purpose or without getting a licence from us. You may not modify, copy, publish, republish, upload, post, communicate or disseminate Content to third parties without our prior written consent. You may not redistribute or re-circulate any Content to any third parties unless using our own emailing tool.
2.4 You may generate tables from the Websites for use in pitch presentations or conferences for as long as you credit the information to us by clearly and legibly specifying the source (for example, www.greenbonddata.org) on the page where the relevant information is displayed.
2.5 Field Gibson Media does not accept use of generic email addresses where access is available to more than one person.
3. Registration and restrictions on ID use
3.1 If you register for a free trial, a subscription or for attendance to one of our Events, you must provide the necessary registration details including accurate payment information.
3.2 It is your responsibility to ensure the accuracy of your registration information and to keep this information up to date on the relevant subscription, Events or free trial page of the Websites.
3.3 On registration for a free trial or a subscription, you will be issued with a password.
3.4 You may not share your password and user name with anyone else. Your password may be used on multiple computers - at home, in the office, whilst travelling - but only computers for your individual use. A password is for one person's use.
3.5 Password sharing is a breach of our terms and conditions and is likely to result in an infringement of copyright. We monitor usage of the Websites to detect password sharing and, if we detect that you have shared your password, we will notify you with details of the incident.
3.6 Password sharing will result in additional subscription costs being levied and / or cancellation or suspension of your access to the Content.
3.7 You are responsible for use of the Websites made by you or anyone else using your user name and password. If you suspect your user name or password have been compromised, you must notify us immediately by emailing us at firstname.lastname@example.org.
5. Third party websites, services and products
5.2 The Websites also contain advertising and sponsorship. Advertisers and sponsors are responsible for ensuring that material submitted for inclusion on the Websites complies with advertising standards and with all applicable national and international law. Field Gibson Media is not responsible for any error or inaccuracy in advertising or sponsorship material.
6. Our responsibility to you - limitation of liability
6.1 We will exercise reasonable skill and care in providing the Websites, Content, Magazine and in organising the Events.
6.2 The extent of our responsibility (liability) to you with regards to your use of the Websites, Content, booking or attending an Event or third party products or services available through the Third Party Websites is set out below:
6.2.1 If you are a subscriber and we breach these terms and conditions, our liability to you for any direct damages incurred from using the Websites or Content is limited to the price you paid for your subscription during the year in which you have incurred the damage.
6.2.2 If you are not a subscriber or you incur any loss using the Websites or Content outside the scope of these terms and conditions, we accept no liability.
6.2.3 In addition, we accept no liability for your use of Third Party Websites or in respect of any products or services you access through the Third Party Websites.
6.2.4 In relation to the Content (including Content provided by third parties and products or services made available to you through Third Party Websites), Field Gibson Media is a provider of information for general information purposes and does not provide financial, tax, legal, accounting or other professional advice. Some Content may contain the opinion of third parties and Field Gibson Media is not responsible for these opinions.
6.2.5 In relation to any Event:
220.127.116.11 views expressed by speakers are their own and Field Gibson Media has no liability in relations to any advice given or opinions expressed by speakers during an Event. Any materials used or distributed at an Event are for general information purposes only and should not be relied upon in making financial, legal, tax, accounting or other decisions;
18.104.22.168 subject to clause 9.7.3, if we cannot meet our obligations under these terms and conditions because of circumstances beyond our control, we will not be held liable for any loss, damage or expense suffered by you or a third party. For example in the case of a last minute change in the content, format, venue or timing of an Event;
22.214.171.124 you are responsible for arranging your own insurance in connection with attending an Event and, subject to clause 6.4, we will not be responsible for any loss or damage to you or your property whilst you are in attendance at an Event; and
126.96.36.199 if we breach these terms and conditions in relation to your attendance to an Event, our liability to you is limited to the fee you paid for the Event.
6.3 The limitations of liability in this clause 6 apply for the benefit of Field Gibson Media, its affiliates and all of their respective officers, directors, employees, agents, successors and assigns.
6.4 Nothing in these terms and conditions shall limit or exclude our liability for fraud or fraudulent misrepresentation, death or personal injury directly caused by Field Gibson Media's negligence.
7. Access - trial and paid subscriptions
7.1 To access the full Content of the Websites, it is necessary to register for a trial or to take a paid subscription.
7.2 Free Trials provisions:
7.2.1 Users may register for a trial by completing the registration form. Whilst most users will be accepted for a trial, completion of the form is not a right to access the Content. Field Gibson Media has complete discretion whether to accept the application and may suspend the trial if it wishes. The trial period shall commence once your application has been accepted which will either be shown on the website or sent in writing and will be for a period agreed by the parties. From time to time, Field Gibson Media may alter the length of a trial. Users will be entitled to one trial only within a period specified by Field Gibson Media. At our discretion, we may extend a user a second trial. If you believe you have a genuine reason justifying a second trial, please email us at email@example.com.
7.2.2 During your free trial, Field Gibson Media will grant you a non-exclusive licence to search and view the Content for the purposes of deciding whether you wish to take a subscription. During the trial, you undertake not to download and save in electronic format, copy and paste, make print outs or copies or modify, publish, post, communicate or disseminate any of the Content.
7.3 Subscription provisions:
7.3.1 You may take out a subscription for a period of either one or two years.
7.3.2 In order to purchase a subscription you must provide complete and accurate payment information. By submitting payment details you are (a) making an offer to us to buy a subscription at the price we have communicated to you and (b) confirming you are entitled to purchase a subscription using those payment details. Once we have verified your payment details and email address and accepted your offer, a contract will be formed and we will provide you with access to your subscription.
7.3.3 Unless otherwise stated, the subscription price excludes VAT. All prices shall be subject to the addition of VAT (where applicable) or any other tax payable as will be indicated on your invoice.
7.3.4 Individual user subscriptions are only available to an individual email address and not to generic email addresses.
7.3.5 Corporate subscription licences may be purchased to allow multiple members of staff with the same email domain address, or with prior agreed email domain addresses, to access our content.
7.3.6 Corporate licences are individually agreed with a representative from Field Gibson Media. Field Gibson Media will discuss with you the benchmark size of the licence and the parameters of the licence with regards to the staff that will be covered i.e individual department, office, country or global. The cost of the licence will depend on the benchmark set.
7.3.7 Once the benchmark is set, Field Gibson Media is happy to add additional users during the year even if these additional users take the number of active email addresses above the benchmark. These users may be added by you contacting Field Gibson Media or by Field Gibson Media identifying new triallists to its Websites that fit the parameters agreed and automatically adding them. This means that the licence may grow during the term of the licence but there will be no extra cost to you. At renewal, Field Gibson Media will give you the option to remove the additional users and remain at the benchmark level or to move to a new benchmark.
7.3.8 You have the option to opt out of auto-adding if you wish, or to ask for all additional users to be run past you.
For payment by card, Field Gibson Media will use all reasonable efforts to safeguard the confidentiality of your credit or debit card details through the use of encryption technology and firewalls. However, "faultless" security does not exist on the Internet. Your card number and contact information will be provided to our subscriptions processor, Recurly, and payment gateway, SagePay, at the time of purchase. Each card company has its own privacy and data collection practices and we have no responsibility or liability for these independent third parties. Recurly is a PCI-DSS compliant Service Merchant Provider, details can be found at http://recurly.com/security.
7.5 Termination and Renewals provisions:
7.5.1 Corporate subscriptions will not be renewed automatically. We will contact you toward the end of your annual subscription to give you the opportunity to consider whether you want to enter into a new annual subscription. We will inform you if we have made any changes to the subscription prices.
7.5.2 For individual subscriptions purchased directly on line by credit card, Field Gibson Media, through Recurly, will hold your card details in order to facilitate the renewal of your subscription at the end of your subscription term.
7.5.3 Individual subscriptions will not be renewed automatically. If you are an individual subscription user, we will email you two months, 30 days and again, 14 days prior to expiry to ask if you wish to renew your subscription. We will communicate at this stage the cost of renewing your subscription. We may also contact you by telephone to discuss your renewal. There is no notice period if you decide not to renew your individual subscription.
7.5.3 If you tell us you want to renew your subscription, we will charge the renewal subscription fee using the payment details you provided during your registration, unless you have notified us of a change to your payment details.
7.5.4 We have the right to increase the price of your subscription with effect from the renewal date. We will communicate any changes in the price in advance of the end of your then current annual individual subscription. If, further to the price increase, you decide to cancel the renewal of your subscription, you must notify us in writing before the end of your current subscription period.
8. Subscriptions - cancellations and refunds
8.1 Unless you cancel your subscription before we have started providing any part of it to you (in which case we will provide you with a full refund) then you agree that once you have started accessing the Websites, you do not have any right to cancel your subscription or any part of it until the end of your then current subscription period. This means you are not entitled to a refund once you have accessed any parts of the Websites that are made available under your subscription.
8.2 Although you may notify us at any time of your desire to cancel, if you do so this will not take effect until the end of your then current subscription period.
8.3 Field Gibson Media may suspend or cancel your subscription if you breach these terms and conditions. We are under no obligation to notify you in advance of doing so or to refund you for all or part of your subscription price paid.
8.4 If Field Gibson Media ceases to provide the Websites and / or subscription services, you will be entitled to a pro rata refund for a payment already made in relation to the remaining period of your subscription.
Subject to availability and acceptance, once we receive the completed booking form for an Event from you, we will confirm your booking in writing (Acceptance). These terms and conditions apply to the contract formed when we confirm our Acceptance.
We accept sponsorship and delegate bookings on the understanding that the programme information listed in the Event documentation is correct at the time of publication but, in certain circumstances, Field Gibson Media may need to change the content, format, venue or timing of an Event. We will notify all delegates of such changes prior to the Event affected by changes.
9.3.1 The Event fee is payable at the time you submit the booking form. Field Gibson Media may change the Event prices at any time but this will not affect registrations which have already been confirmed by us. We cannot guarantee your place until you have paid the Event fee. The Event fee does not include any travel to or from the Event and any accommodation costs incurred.
9.3.2 Unless otherwise stated, the Event fee excludes VAT. All prices shall be subject to the addition of VAT (where applicable) or any other tax payable and such taxes will be indicated on your invoice.
9.3.3 At our discretion, we may offer you a discount on Event fees if you are a holder of an individual or corporate subscription.
Our usual term of accounts is thirty days, however all delegates must settle their accounts in full by the start of the Event. If we have not received payment in full by the start of the Event, we reserve the right to refuse you entry or request a credit card guarantee on the day to gain entry.
9.5 At the Event:
9.5.1 Please let us know at the time of booking if you have any special access requirements. If you notify us of any dietary requirements at least seven days before the Event, we will make every effort to try to accommodate your requirements. Please note that we might not be able to provide you with a suitable alternative if we receive notification about your dietary requirements less than seven days before the Event.
9.5.2 Without our prior written consent, Field Gibson Media does not allow recording of or photography at the Event by delegates or sponsors.
9.5.3 On the day(s) of the Event whilst you are in attendance, we are not responsible or otherwise liable to you for any loss or damage to your personal property unless caused by our own negligence.
9.5.4 You must comply with all rules, regulations, and other reasonable instructions of the owner of the venue at which the Event is taking place and we reserve the right, without any liability, to refuse admission or eject you from the Event if you fail to comply with these terms and conditions or if, in our opinion, you represent a security risk, nuisance or annoyance to the running of the Event.
9.5.5 It is not permitted to reproduce materials distributed at an Event for commercial purposes.
9.5.6 Please indicate your permission for us to use photos taken at Events by Field Gibson Media on the delegate form when registering for an Event.
9.6 Your details:
9.6.1 By registering as a delegate to one of our Events you agree that your contact details may be passed on to the sponsors and exhibitors of that Event. Your details will not be passed on to any other third parties. If you do not agree for your contact details to be passed on to the sponsors and exhibitors of the Event please inform us in writing at the time you make the booking.
9.6.2 Unless you specify otherwise in writing, by registering to attend an Event, you agree to us publishing your name and your company's name in the conference brochure or relevant Event App where we list the attendees.
9.7 Cancellation provisions:
9.7.1 If you wish to cancel a booking with us, we will offer a full refund less a 10% administration fee on cancellations received in writing 30 or more days prior to the Event. If you do not attend the Event or notify us of your intention to cancel within less than 30 days prior to an Event, the Event fee will be payable in full. Any refunds you are entitled to under this provision may take up to 14 working days to process.
9.7.2 If you have difficulty in attending an Event you have registered for, you are welcome to provide a substitute delegate, but we request you inform us of the change as soon as possible and no later than 24 hours before the start of the Event.
9.7.3 If, due to significant changes we make to the date or venue of an Event (for example where the new venue is more than 10 miles from the original venue) you are not able to attend, we will refund any Event fee you have already paid within 15 working days.
9.7.4 Field Gibson Media will send any refund due under this provision using the same payment method you employed for paying the Event fee.
9.7.5 If you cannot attend an Event you have registered for, contact us on firstname.lastname@example.org as soon as possible.
10.1 You may not assign or transfer any of your rights or obligations under these terms and conditions without our prior written consent, which may not be unreasonably withheld or delayed. We may transfer any of our rights or obligations under these terms and conditions to any affiliated company or, with your prior written consent not to be unreasonably withheld, to any other party.
10.2 If any provision of these terms and conditions that is not fundamental is found to be invalid, illegal or unenforceable by any court having competent jurisdiction, the invalidity, illegality or unenforceability of that provision will not affect the validity of the remaining provisions of these terms and conditions, which will remain in full force and effect.
10.3 If either party delays or fails to exercise any right or remedy under these terms and conditions, it will not have waived that right or remedy.
10.4 The terms and conditions shall be governed by and construed in accordance with the laws of England and Wales. Any disputes arising from matters relating to these terms and conditions shall be subject to the exclusive jurisdiction of the courts of England and Wales.
10.5 These terms and conditions contain the entire agreement between you and Field Gibson Media.
These terms and conditions were updated on 05 January 2021 and replace our previous terms and conditions.
Field Gibson Media Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our websites as well as your privacy rights and how the law protects you. The websites covered by this privacy notice are as follows: www.environmental-finance.com, www.insuranceerm.com, www.insuranceassetrisk.com, www.insuranceriskdata.com, www.fieldgibsonmedia.com and www.bonddata.org ("Websites").
1. Important information and who we are
Field Gibson Media Limited of Pentagon House, 52-54 Southwark Street, London SE1 1UN, registration number ZA098022 is the controller and responsible for your personal data (referred to as "we", "us" or "our" in this privacy notice).
If you have any questions about this privacy notice or how we protect or use your personal data, please contact our Data Protection Officer. The Data Protection Officer can be contacted as follows:
Post: Data Privacy Officer, Field Gibson Media Limited, Pentagon House, 52-54 Southwark Street, London SE1 1UN
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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
We keep our privacy notice under regular review. This version was last updated on 3 November 2020.
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.
The Websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Websites, we encourage you to read the privacy notice of every website you visit.
2. The data we collect about you
"Personal data", or "personal information", means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes title, first name, last name and username or similar identifier.
- Contact Data includes email address and telephone number.
- Financial Data includes payment card details (we comply with all requirements of the Payment Card Industry Data Security Standards (PCI DSS) with respect to the storage, processing and transmission of payment card data).
- Transaction Data includes details about payments from you and other details of services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Websites.
- Profile Data includes your username and password, purchases made by you, your interests, preferences and survey responses.
- Usage Data includes information about how you use our website and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- create an account on our Websites;
- set up a trial subscription to our service or publications;
- subscribe to our service or publications;
- supply information for publication on our Websites;
- complete an enquiry form;
- request marketing to be sent to you;
- participate in surveys or research; or
- give us feedback or contact us.
- Publicly available information. We may collect your corporate contact details from publicly available sources such as the website of your company on the internet.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Performance of a contract: where we need to perform the contract we are about to enter into or have entered into with you.
- Legitimate interests: where it is necessary for our legitimate interests (or those of a third party) e.g. in the interest of conducting and managing our business to give you the best service and the most secure experience. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
- Legal compliance: where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.
|Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you for a trial subscription or to register you as a new subscriber
|Performance of a contract with you
|To process and deliver your order including:
- Manage payments
- Collect and recover money owed to us
- Marketing and Communications
- Performance of a contract with you
- Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
- Notifying you about changes to our terms and conditions or privacy notice
- Asking you to leave a review or take a survey
- Marketing and Communications
- 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 services)
|To administer and protect our business and the Websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
- Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
- Necessary to comply with a legal obligation
|To provide reports to our clients containing information about usage under corporate licenses
|Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)
|To publish information you have supplied to us on the Websites, where you have supplied information to us for such purposes
|Necessary for our legitimate interests (for running our business)
|To enable us to deal with any complaints or queries raised by you
|Necessary for our legitimate interests (to improve our services)
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
- Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)
|To use data analytics to improve our Websites (e.g. by ensuring content is presented to you most effectively), services, marketing, customer relationships and experiences
|Necessary for our legitimate interests (to define types of customers for our services, to keep our Websites updated and relevant, to develop our business and to inform our marketing strategy)
|To make suggestions and recommendations to you about services that may be of interest to you
- Marketing and Communications
|Necessary for our legitimate interests (to develop our services and grow our business)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can amend your marketing preferences at any time by contacting us.
You will receive marketing communications from us if you have requested information from us, registered for a trial subscription or purchased a subscription from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for general marketing purpose. When it comes to the management and organisation of events and conferences, we may share your personal data with our sponsors, partners and co-organisers if we deem it legitimate interest and beneficial to operating of the event in the virtual environment.
You can ask us or third parties to stop sending you marketing messages about a particular event or certain news alerts at any time by following the opt-out links on the relevant marketing message sent to you. Alternatively you can unsubscribe from all marketing messages by contacting us.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase or other transaction.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may share your personal data with the persons set out below for the purposes set out in the table above.
- Lead sponsors at events where you are a delegate.
- Advertisers and advertising networks that require the data to select and serve relevant adverts to you provided that you have consented to such data sharing.
- Analytics and search engine providers that assist us in the improvement and optimisation of the Websites.
- Service providers who provide IT and system administration services based in Croatia.
- Payment processing service providers.
- Professional advisers including lawyers, bankers, auditors and insurers based in the UK.
- HM Revenue & Customs and other UK authorities or regulators whom require reporting of processing activities in certain circumstances.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
Some of our service providers are based outside the European Economic Area ("EEA") so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has inside the EEA.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
How long will you use my personal data for?
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
If you wish to exercise any of the rights set out below, please contact us.
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Further information about your rights
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.