Jefferson Group Website Privacy Notice – February 2019

The term Jefferson Capital Ltd or 'us' or 'we' refers to the owner of the Website whose registered domain is https://jefferson-capital.com. Our company registration number is registered in England and Wales with company registration number 10338132. The term 'you' or 'your' refers to the user or viewer of our Website.

This privacy notice sets out the processing practices in relation to personal data which is collected, stored and retained through the use of this Website and any other electronic communications by Jefferson Capital , which is the data controller for that data.

Your right to privacy is important to us. This privacy notice sets out how Jefferson Capital uses and protects any information that you give us when you use this website. We are keen to strike a fair balance between your personal privacy and ensuring that you obtain full market value from the internet and other products and services we may market to you.

If you do not agree to the following policy, you may wish to cease viewing/using this Website, and or refrain from submitting your personal data to us.

We may change this notice from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This notice is effective from 22nd March 2019.

For the purposes of meeting the Data Protection Act 2018 territorial scope requirements, the United Kingdom is identified as the named territory where the processing of personal data takes place.

If you have any requests concerning your personal data or any queries with regard to this notice, please contact Jefferson Capital at info@jefferson-capital.com. We are registered with the Information Commissioner’s Office (ICO); our registration number is ZA291413. Information on the Data Protection Act 2018 and the General Data Protection Regulation (the GDPR) is also available on the Information Commissioner's website at www.ico.gov.uk. Under the GDPR, your individual rights in relation to your personal data are as follows (you can read more about your rights in detail at https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/);

  • the right to be informed about the personal data being processed
  • the right of access to the data
  • the right to rectification
  • the right to erasure
  • the right to restrict processing
  • the right to data portability (to receive an electronic copy of your personal data)
  • the right to object to processing of your personal data and
  • the right not to be subject to automated decision-making. including profiling

Personal data we collect

We may collect and process the following data:

  • Information about you such as name, title, date of birth, gender, nationality, country of birth, country of residence, employment status, email address, post code, contact number. We require this information not only to help us to identify you, but also to allow us to contact you;
  • Government Identification documentation such as Passport details, Driving Licence, National Insurance Number, Tax Identification Number and utility bills;
  • Government Records that may be held by financial crime prevention agencies, the Electoral Register and by Utility Services providers;
  • Financial Information such as bank account details for payments made to Jefferson Capital or payments Jefferson Capital make to you;
  • Income/Wealth such as your employment status, income and source of wealth;
  • Contractual Information such as details regarding your products and benefits that we may provide;
  • Third Party information, where relevant such as your IFA , Intermediary, Executor, or any Power of Attorney etc.;
  • Online Information such as – cookies and IP address, if you use our website
  • Audio Recordings such as voice recording if you, or your IFA or Intermediary, contact us. These are recorded for regulatory purposes.

Full details of the purposes for collecting Personal Data are set out in our Data Protection registration with the ICO under Registration Number: ZA291413. https://ico.org.uk/ESDWebPages/Entry/ZA291413

Any personal information you provide to us through this website will be dealt with in accordance with this Privacy & Cookie Policy, the Terms and Conditions of use of this website and, any signed authority form that you give to us.

Use of personal data

We collect and process your data for one or more of the following grounds:

This will depend on which category you fit into and the processing carried out by us directly or trusted third party companies that we use.

We use information in the following ways:

  • to provide our services to you;
  • Processing your investment application;
  • Where we have an obligation to do so, such as identification verification with fraud prevention agencies to enable us to comply with our anti-money laundering obligations and for the purposes of crime and fraud prevention and to protect our business interests;
  • To help protect your information and prevent unauthorised access to it;
  • To comply with our obligations arising from any agreements entered into between you, your IFA and Jefferson Capital ;
  • Carry out regulatory checks and meet any legal or regulatory obligations;
  • Producing tax reports such as a Consolidated Tax Voucher, CGT Report etc.,
  • Completing any enquiry or requests you may make;
  • Keeping you updated with regular/quarterly reports;
  • Sending you marketing emails to keep you informed about products and services you hold with us that may be of interest to you. (You may opt out of receiving this information when we collect your details or at any time by contacting us);
  • Maintaining a backup of our investment register for Business Continuity purposes;
  • Where we have an obligation in law and to the extent necessary for the proper operation of our systems
  • To notify you of any changes to our services, and
  • To help improve the services that we provide to you.

Who We Share Your Data With

We will endeavour to maintain such information in accordance with our internal policies governing the use and disclosure of confidential information and will only use it for the stated purpose. We will not share this information with any third party outside Jefferson Capital , other than with relevant Service Providers to enable them to assist in providing, maintaining and operating the Services, unless we have your prior permission to do so or are required to do so by law.

We may share your personal information with the following third parties:

  • Our Service Providers and Agents (including their sub-contractors) and in order to provide and maintain the provision of the services, such as:
  • Our custodian
  • IT companies who support our technology;
  • Offsite storage firms;
  • Confidential waste disposal;
  • Printing firms
  • require access to the information in order to advise us;
  • HM Revenue & Customs;
  • Regulators such as the Financial Conduct Authority (FCA), Information Commissioner (ICO) and other authorities as required;
  • UK Financial Services Compensation Scheme (FSCS);
  • Introducing firms;
  • Our external agencies who will only contact you when requested by us to do so for the purpose of improving our service to you;
  • Anyone to whom we may transfer our rights and/or obligations under the Agreement;
  • Any person notified by you as authorised to give instructions for the purposes of managing or administering the service provided under your Agreement with us, to the extent reasonably necessary to enable us to perform the services.
  • Any person that you request us to share your information with;
  • Where Jefferson Capital has a duty to do so to meet applicable law and regulatory requirements, or if law or regulation allows us to do so.

Jefferson Capital will not lend or sell your information to third parties, but we may provide access to your personally identifiable information when legally required to do so, to cooperate with police investigations or other legal proceedings, to protect against misuse or unauthorised use of our website, to limit our legal liability and protect our rights, or to protect the rights and safety of visitors to our website. In those instances, the information is provided only for that limited purpose.

International Transfers - Sharing Your Information Outside The European Economic Area (EEA)

Subject to applicable law, Jefferson Capital may share your personal information with our service providers and this may involve transferring it to countries outside the EEA whose data protections laws may not be as extensive as those to which this Policy applies. Where we share information with organisations in another jurisdiction, we will ensure that we do this in accordance with the Data Protection Laws and Regulations and take appropriate measures to ensure they agree to apply equivalent levels of protection. We will further ensure that we include conditions in the contract to protect all personal information to the standard required in the EEA.

How long do we keep personal data?

We will keep your personal data only for so long as it is reasonable for us to do so, depending upon the nature of the data and our processing, and the grounds upon which we collected it. In general, we will delete redundant account information within 14 days of our relationship ending. However, we are obliged to keep certain records of our relationship to comply with the FCA’s and other regulatory rules, in which case we will instead restrict access through our archiving processes. Subject to any actual or potential legal claim or regulatory investigation, the maximum time that we envisage retaining any of your information is seven years, after which time it will be destroyed.

Information we use for marketing purposes will be kept by us until you notify us that you no longer wish to receive this information. If you do notify us that you no longer wish to receive marketing information we will keep an encrypted version of your contact information to ensure we respect your wishes.

Confidentiality & Security

Jefferson Capital will endeavour to maintain confidential information in accordance with our internal policies governing the use and disclosure of confidential information and will only use it for the stated purpose. We take the protection of your personal data very seriously and take appropriate steps to ensure your personal data is stored in a secure environment to prevent any unauthorised access. We will not share this information with any third party outside JEFFERSON CAPITAL unless so required by law. For example, with authorities as the FCA or with any other regulatory authority to which we are subject or with any person empowered to require such information by or under any legal enactment.

Where Jefferson Capital use external data service providers to process personal data on our behalf to enable them to assist in providing, maintaining and operating the Services required to fulfil our obligations to you, we will always ensure that we hold appropriate agreements in place to protect your data. Any data transfers between JEFFERSON CAPITAL and its external service providers are conducted by secure means. Where such service providers are located outside the EEA, JEFFERSON CAPITAL have additional contractual arrangements in place.

What are your rights?

You have the right to request information on and access to the personal data we hold about you.

You also have the right to request that we correct or delete any incomplete, incorrect, unnecessary or outdated personal data we hold about you. However, we cannot delete personal data that is necessary for compliance with our binding legal or regulatory obligations or if the personal data must be retained according to applicable laws, or is required for the exercise or defence of a legal or regulatory claim.

In case you consider your personal data collected by us to be inaccurate but you do not wish your personal data to be deleted, if we have used your personal data unlawfully or you have objected to the processing and the existence of legitimate grounds for processing is still under consideration, you may request restriction of processing of your personal data.

You may also at any time object to your personal data being processed for direct marketing purposes, sending promotional materials, profiling, or for the performance of market research. Where your personal data is processed based on your consent, you have the right to withdraw your consent for such processing at any time.

In case you wish to make use of your rights mentioned above, you may, as appropriate and in accordance with applicable laws, exercise such rights by contacting us through the contact points referred in the marketing materials or below in this notice. In some cases, especially if you wish us to delete or cease the processing of your personal data, this may also mean that we may not be able to continue to provide the services to you.

Please note that we may need to identify you and to ask for additional information in order to be able to fulfil your requests. Please also note that applicable law may contain restrictions and other provisions that relate to your above rights.

Subject access rights

You have a right to a copy of and details of the personal data held about you. To obtain a copy of the personal data Jefferson Capital holds about you, please write to us at info@jefferson-capital.com. No charge will normally be made by Jefferson Capital for providing this information. If your request is considered to be repetitive, wholly unfounded and/or excessive, we are entitled to charge a reasonable administration fee.

Other websites

Our website may contain links to other websites which are outside the control of Jefferson Capital and are not covered by this privacy notice. If you access other websites using the links provided, the operators of these websites may collect information from you which will be used by them in accordance with their privacy notice which may be different to the privacy notice of Jefferson Capital. You should exercise caution and look at the privacy notice applicable to the website in question.

Transfers of your personal data

Generic service providers (data processors)

We may transfer your personal data to third parties who process personal data on our behalf to enable the efficient technical and logistical provision of our services. These service providers may, for instance, supply us with cloud data storage, data security services, customer relationship management software, and other support services. We may substitute a technical or logistical service provider from time to time. Such parties are generally not permitted to use your personal data for any other purposes than that for which your personal data was collected, and we require them to act consistently with applicable laws and this Privacy notice as well as to use appropriate security measures to protect your personal data.

Event-driven transfers

We may transfer your personal data to third parties in certain events where it is necessary to protect your, or our, legitimate interests. This includes the cessation, sale or transfer of our business, civil or criminal legal, or regulatory, proceedings or insurance claims.

International transfers

Our products and services may be provided using resources and servers located in various countries around the world. Therefore, your personal data may be transferred outside the country where you use our services, including to countries outside the European Economic Area (EEA). We will transfer data in such circumstances only if the level of data protection in that jurisdiction is deemed adequate and if there are appropriate safeguards in place to protect your privacy.

Given that the Internet is a global environment, using the Internet to collect and process personal data necessarily involves the transmission of information on an international basis. Therefore, by browsing the Website and communicating electronically with us, you acknowledge and agree to Jefferson Capital processing personal data in this way.

Cookies

The Use Of Cookies, Tags & Similar Technologies

When data is provided to JEFFERSON CAPITAL , it is used solely for the purposes for which it has been given. We may use cookies and similar technologies on our websites and in our emails. A cookie is a small piece of code, sent from a website to a user's internet browser, which allows that website to track the user's previous activity when they return to that website. This allows us to provide you with the experience that you expect from us and lets us continually improve our service.

You can block cookies by changing the settings on your browser, but if you do you will not be able to access all or parts of our website.

How And Why We Use Cookies

Cookies to collect information about how our visitors use our website, such as to:

  • give you the best experience when you visit our website
  • facilitate our clients’ use of our website
  • allow us to provide a service whereby people can access and manage their account
  • provide online Fact Sheets, Brochures, Research, Quarterly Commentaries, Quarterly Fact Sheets, Terms of Business, User Guides Forms and Videos;
  • monitor the number of visitors to our site and collectively monitor their activities (we cannot identify where you, as an individual, are located or the software or services you are using)
  • understand more about the way in which people use our Website

The cookies collect information in an anonymous form, including the number of visitors to the site, what pages they have visited. which enable us to compile reports and to help us improve the website.

Cookies used by the Jefferson Capital website DO NOT:

  • allow us to identify what you, as an individual, do on our website or what your individual preference or settings are;
  • contain any personally identifiable information about you or information such as passwords;
  • allow us to access other information stored on your computer, Smartphone or web-enabled device to obtain information about you and your family, or read any material kept on your hard drive;
  • give us information about other websites you visit and use;
  • detail your activities on other websites;
  • store any information about you that others could read and understand;
  • store information that may compromise your security.

The types of cookies we may use are:

Strictly necessary cookies.

These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website. or make use of e-billing services.

Analytical/performance cookies.

These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

Functionality cookies.

These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Targeting cookies.

These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Using Browser Settings To Manage Cookies

Most web browsers allow you to manage cookies via the browser settings. For example, you may choose to delete existing cookies, prevent your browser from accepting new cookies, have the browser notify you when you receive a new cookie or disable cookies altogether.

Please note: if you share the use of a computer or web-enabled device, accepting or rejecting the use of cookies will affect all users of that computer or web-enabled device.

You can control how cookies are placed on your device and remove existing cookies by changing your web browser settings.

We do not have any control over the use of cookies by third parties, including our partners and affiliates. To manage cookies from third party websites, you will need to visit their site to adjust your settings.

We Regularly Review Our Privacy & Cookie Policy

We may change the content found on our website at any time, without prior notice therefore you should read our Privacy and Cookie Policy each time you use this site as access to or use of this site means that you agree to the version of the Privacy and Cookie Policy in effect on each visit to our site.

Contact Us

If you have any questions or concerns with regards to this Privacy & Cookie Policy, or if you aren’t happy with the way we use your information, please contact us using the details below:

Jefferson Capital
30th Floor, 40 Bank Street
London E14 5NR
United Kingdom
Email: info@jefferson-capital.com

If you want more information about how cookies operate, or how to manage them, please visit About Cookies at http://www.aboutcookies.org.uk/.

Use of this website is subject to our terms of use. (https://jefferson-capital.com/terms.html)