Privacy Policy

Systematic Finance is a controller of your personal data.  We respect your data and your privacy is important to us.

This Privacy Policy explains what personal data we collect and how it is used.  This notice also explains what rights you have over your personal data and how you can use those rights. 

You have the right to object to some of the processing which Systematic Finance Limited carries out.  More information about your rights and how to exercise these is set out in the “Your rights” section of this notice.

Systematic Finance ’s registered office is Orchard House, Green Lane, Guildford GU1 2LZ, UK. 

1. Summary of how we use your data and your rights
2. Information we collect from you
3. How we use information and the legal basis
4. International transfers
5. Data retention
6. Your rights
7. Contact details
8. Which company is the controller?

1. Summary of how we use your data and your rights

We use your data to provide and improve our products and services, including for marketing, research, feedback and enquiries, and for safety and security purposes. 

We will use your data to comply with laws and regulations. We may use your data to prevent and detect crime, such as fraud. 

You have the right to object to some of the processing Systematic Finance carries out. More information about your rights and how to exercise these is set out in the “Your rights” section of this notice. 

When you give consent, you can withdraw that consent at any time, for instance by emailing [email protected].  You can also email [email protected] to exercise any other data rights, such as obtaining a copy of your data, correcting, deleting or restricting how we use your data.  Please see “Your rights” for more information.

You can unsubscribe from marketing communications at any time.  To opt out of marketing, including profiling for direct marketing purposes, you can select “unsubscribe” in emails, or email [email protected].

If you enable location services and you access the location finder on our sites and your browser settings allow this, your device will identify your location to Systematic Finance.

2. Information we collect from you

We collect information when you purchase something or use our services.  This includes using our websites or corresponding with us. 

In particular:

• We keep information you give us directly such as contact details (including name, email, address and telephone number), comments, region and feedback.

• We record and analyse web visits and details of your purchases.
  
  
• If there is an incident, we may need to log information about it.

• If you post information online about us or provide feedback, we may keep a record.

• If you contact us directly or give feedback, we will record details and all related information such as emails, letters and phone calls.

3. How we use information and the legal basis

We can use your data only if we have a proper reason to do so such as: 

• To fulfil a contract we have with you;
  
  
• When it is in our legitimate interest;
  
  
• When you consent to it; or
  
  
• To comply with the law.

A legitimate interest is when we have a business or commercial reason to use your data. This involves us assessing when we can rely on our legitimate interests. For more information on this assessment please contact [email protected].

We have set out below how and why we may use your personal information and the legal basis we rely on. This is also where we tell you what our legitimate interests are.
We take information to communicate with you, check your identity, take payment, and provide products and services.

Our legitimate interests include keeping our records up to date, fulfilling our legal, compliance and contractual duties, working out which of our products and services may interest you, improving our site and services, developing new products and services, and telling you about them and conducting market research. 

To run and promote our business, we use your information:

• To provide and improve our products and services and to respond to you if you contact us.

• When we monitor social media platforms such as Facebook and Twitter and online services including our mobile apps and responses to email marketing. If you post comments online or in other media we may capture this information, contact you, and use it to improve our products and services.

• To understand you better as a customer by analysing your transactions and other information you provide to us or which we learn through your interactions with us.

• To contact you where you provide us with market research feedback or pass this data to a third-party business partner of ours for panel market research analysis.

To comply with law, assess and uphold legal or contractual rights and claims, and for monitoring, auditing and training on compliance matters:

• We keep records and pass your data to our insurers and legal advisors when necessary (for further details see Data sharing below).

• We may verify your identity. 

When you give consent, you can withdraw that consent at any time by contacting us, for instance by emailing [email protected].  If you do so we can only continue to use your data if another legal basis applies, such as when we’re required to do something by law.
 
Nevertheless, you have an absolute right to opt-out of direct marketing, including profiling for direct marketing purposes, at any time.  You can opt out of marketing by selecting “unsubscribe” in emails or by [email protected].

4. International transfers

In rare occasions we may need to send or store your data outside of the European Economic Area (the EU plus Iceland, Lichtenstein and Norway) (‘EEA’).  For example, to follow your instructions, comply with a legal duty or to work with or receive services from our service providers who we use to help run your accounts and our services.

If we do transfer information outside of the EEA, we will make sure that it is protected by using one of these safeguards:

• Transfer it to a non-EEA country with privacy laws that give the same protection as the EEA. Some countries have been deemed adequate by the EU.

• Put in place a contract with the recipient that means they must protect it to the same standards as the EEA or use other mechanisms and measures to achieve adequate protection. We also may use the Standard Contractual Clauses published by the EU.

• Transfer it to organisations that are part of Privacy Shield. This is a framework that sets privacy standards for data sent between the US and EU countries. It makes sure those standards are similar to what is used within the EEA. 

• Binding corporate rules. These are internal rules adopted by group companies to allow international transfers of personal data to entities within the same corporate group located in countries which do not provide an adequate level of protection.

5. Data retention

We keep your data to enable us to fulfil our contract with you or to provide services, whilst you are an active user of our site and services where required by law or to protect legal rights.

We always look to keep your data for the minimum time in line with data protection principles and our processes.  For example, we keep:

• Information on clients.

• Records of payment information in line with tax law and audit requirements.

• Customer feedback and correspondence with our customer services teams for up to two years afterwards, depending on the nature of the interaction and any applicable law, such as health and safety.  This enables us to respond to any questions or complaints.

• Information to maintain records according to rules that apply to us.

If you unsubscribe from marketing communications we keep a record of this request indefinitely to ensure we do not send you direct marketing again.

We may keep your data for longer if we cannot delete it for legal, regulatory or technical reasons.

6. Your rights

You have rights over your personal data. You can:

• Ask for a copy of your information;
   
  
• Ask for information to be corrected;
  
  
• Ask for information to be erased or deleted; 
  
  
• Ask for us to limit or restrict processing;
   
  
• Object to us processing your data, in particular where we use the data for direct marketing, including profiling for direct marketing purposes.  The right to object does not apply if we must process the data to meet a contractual or legal requirement;
  
  
• Ask us to send you a copy or ask for us to send it to another party.
  

Some rights, however, may be limited. We may be obliged by law or regulation to keep information.  We must respect other people’s privacy as well, which means we may need to redact or remove information where it includes personal data about someone else, even if it is connected to your data.  On occasion there may be a compelling legitimate interest to keep processing data.

If you want a copy of your data, to object to how we use your data, or ask us to delete it or restrict how we use it or, please see ‘Contact details’ below.  To process a request from you, we may need to confirm your identity to ensure we’re accessing the right data.
You have a right to complain to an EU data protection authority.  This can be where you live, work or where the matter occurred. In the UK, the authority is the Information Commissioner’s Office (the “ICO”).

7. Contact details

To exercise any of your rights or to withdraw consent you can email [email protected].

For any queries relating to data protection please contact [email protected] or by write to the Privacy Officer, Systematic Finance, Orchard House, Green Lane, Guildford GU12LZ, UK.

If we make any changes or updates to this notice we will communicate these to you.

8. Which company is the controller?

The controller for your information is Systematic Finance, Orchard House, Green Lane, Guildford GU12LZ, UK. (Registered in England and Wales Number 2443802).