Privacy & Cookies Policy

Welcome to Greyfriars Investments Ltd privacy notice.

Greyfriars Investments Ltd is committed to respecting your privacy and protecting your personal data. This privacy notice informs you about the data processing practices carried out by Greyfriars Investments Ltd and also tells you about your privacy rights and how the law protects you.

If you have any requests concerning your personal information or any queries with regard to our practices, please contact our Data Controller, Greyfriars Investments Ltd, 56 George Street, Edinburgh, EH2 2LR, telephone 0131 220 6719 or info@greyfriarsinvestments.co.uk

Purpose of this Privacy Notice

This privacy notice aims to give you information on how Greyfriars Investments Ltd, collects and processes your personal data, including any data you may provide to us from time to time.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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 notice supplements the other notices and is not intended to override them.


Contents

1. Who we are and the information that we collect

2. Use of personal information

3. Other websites

4. Your information
4.1 Collecting your information
4.2 How we use your data
4.3 Keeping your data safe
4.4 Keeping your information up to date
4.5 Sharing information
4.6 Your data rights & right of erasure

5. Data Retention

6. Amendments

7. About cookies
8. Cookies that we use
9. Cookies used by our service providers
10. Managing cookies


1. Who we are and the Information we collect

We are: Greyfriars Investments Ltd, a company set up in Scotland company number SC515929.

Greyfriars Investments Ltd’s registered offices is at 56 George Street, Edinburgh, EH2 2LR (“we”, “our” and “us”). We are data controller of any personal data that you provide us.

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 collect information from you when you enquire about our activities and services, make an enquiry through any of our websites or if you otherwise provide us with personal information, for example, in person, over the phone, online, on paper or by SMS. This includes any interactions you may have with our staff members, consultants or contractors legally working on behalf of us.

We may collect, use, store and transfer the following kinds of personal data about you:

Identity Data: includes first name, maiden name, last name, or similar identifier, marital status, title, date of birth and gender.

Contact Data: includes company name, address, email address and telephone numbers.

Financial Data & Anti Money Laundering Data: copies of driving licence; passport, bank accounts, address verification.

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 routinely collect any information about criminal convictions and offences.


2. Use of personal Information

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:

  • Where we need to perform the contract/transaction we are about to enter into or have entered into with you;
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
  • Where we need to comply with a legal or regulatory obligation e.g. Anti-Money Laundering.

We usually 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.

We may send you information about Greyfriars Investments Ltd’s activities according to the preferences you may agree. If you would like to update your preferences at any point, please email us at info@ greyfriarsinvestments.co.uk

Alternatively, you can also write to us at Greyfriars Investments Ltd, 56 George Street, Edinburgh, EH2 2LR.


3. Websites

Our website (greyfriarsinvestments.co.uk) may link to other websites that are outside our control and are not covered by this Privacy Policy. If you access other sites using the links provided, the operators of these sites may collect information from you that will be used by them in accordance with their privacy policy, which may differ from ours. Please check their terms and conditions.


4. Your information

4.1 Collecting your information

We collect your information in the following ways:

When you provide it to us DIRECTLY
You may give us your information to engage our services, as part of us discussing/progressing a transaction or contract, communicate with us generally, participate in an event, or opt in to receiving communications from us via our website or through an email.

Information available publicly
If your information is available publicly, this may include information found in places such as Companies House, the electoral roll and information that has been published in articles/ newspapers.

4.2 How we use your data

The type and quantity of information we collect and how we use it depends on why you are providing it. If you contact us to engage our services, we will usually collect:

Identity Data: includes first name, maiden name, last name, or similar identifier, marital status, title, date of birth and gender.

Contact Data: includes company name, address, email address and telephone numbers.

Financial Data & Anti Money Laundering Data: copies of driving licence; passport, bank accounts, address verification.

We use your data to:

  • Provide you with services or information you have requested
  • Keep a record of your relationship with us
  • Ensure we know how you would like us to stay in touch
  • Understand how we can improve our services and information

We may also use your personal information to detect and reduce fraud and credit risk.

4.3 Keeping your data safe

We will ensure that there are always appropriate technical controls in place to protect your personal details. We undertake regular reviews of who has access to information that we hold to ensure that your information is only accessible by appropriately trained staff and contractors.

We may be asked to disclose your details to the police, regulatory bodies or legal advisors and will so do when bound by law.

4.4 Keeping your information up to date

We use publicly available sources to keep records up to date, we also rely on you to let us know of any changes to your contact details.

4.5 Sharing information

We may, where necessary, share your information with:

  • Partners connected to the transaction we are progressing with you, e. g. Banks. This will only be done with your prior consent.

We will never sell or swap your personal details with other organisations for their marketing purposes.

If at any point you would like to discuss any concerns, please contact us on 0131 220 6719 or email info@greyfriarsinvestments.co.uk

You have a right to ask for a copy of the information we hold about you and a right to make a complaint to the Information Commissioners Office if you believe we are not handling your data correctly.

If you want to access your information, please email a description of the information you want to see and proof of your identity to info@greyfriarsinvestments.co.uk or by post to: Data Controller, Greyfriars Investments Ltd, 56 George Street, Edinburgh, EH2 2LR. This information will be provided to you by email (or post) within one month of the receipt of your request free of charge.

If you have a concern about the way in which we are handling your personal information and you wish to complain to the Information Commissioner, you can do so here or by calling 0303 123 1113.


5. Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.


6. Amendments

We may change this privacy policy from time to time. Any significant changes will be detailed on our website or we will make contact with you directly.

This privacy policy was last updated on 01/05/2018.


7. About cookies

7.1    A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

7.2    Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

7.3    Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.


8. Cookies that we use

8.1  We use cookies for the following purposes:

(a)    authentication – we use cookies to identify you when you visit our website and as you navigate our website;

(b)    status – we use cookies to help us to determine if you are logged into our website;

(c)    personalisation – we use cookies to store information about your preferences and to personalise the website for you;

(d)    security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;

(e)    advertising – we use cookies to help us to display advertisements that will be relevant to you;

(f)    analysis – we use cookies to help us to analyse the use and performance of our website and services; and

(g)    cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.


9. Cookies used by our service providers

9.1  Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

9.2  We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: www.google.com/policies/privacy.


10. Managing cookies

10.1  Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a)    https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b)    https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c)    http://www.opera.com/help/tutorials/security/cookies/ (Opera);

(d)    https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e)    https://support.apple.com/kb/PH21411 (Safari); and

(f)    https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

10.2  Blocking all cookies will have a negative impact upon the usability of many websites.

10.3  If you block cookies, you will not be able to use all the features on our website.