This privacy notice tells you what to expect when bfinance collects personal information. It applies to information we collect about:
visitors to our websites
survey information we may collect
people who use our services, e.g. who subscribe to our newsletter, request a publication from us or access our Investment Manager Portal
Changes to this policy
1. Data we collect
1.1 Sign up to our newsletter
To sign up for our newsletter you only need to provide us with your email address. We use the double opt-in method for all our email newsletter sign-ups. The double opt-in process includes two steps. In step 1, a potential subscriber fills out and submits our online signup form. In step 2, they'll receive a confirmation email and click a link to verify their email, which is then added to our mailing list. You can change your mind at any time during this process and unsubscribe using the email link provided at the bottom of all bfinance newsletter emails.
1.2 White paper downloads
1.3 Job application forms & recuitment
As new job vacancies arise at bfinance, we may use web forms on our website to gather initial applications for the position advertised or you may choose to email us directly with your application. We will gather your name, address and contact details, including email address and telephone number. We may also gather information such as details of your qualifications, skills, experience and employment history should you choose to upload or send us your curriculum vitae.
We may also gather information through publicly available sources with professional relevance:
Professional social media and networking sites (including LinkedIn)
Job Boards that you have registered your details on
Online curriculum vitae libraries
1.4 Contact forms
We collect your name and email address when you submit our contact form. When you fill out this form you will also have the option to subscribe to our email newsletter. If you opt in to our newsletter at this point we will also send you a confirmation email as described in the newsletter sign up process above.
1.5 Investment Manager Portal - impp.bfinance.com
Should you wish to be kept up to date with current manager selection opportunities, investment managers can register for an account on our investment manager portal. During the sign up process we will collect your name, email address, telephone number, job title and the company you are currently employed with.
bfinance reserve the right to restrict access to our newsletter sign up, white paper downloads and Investment Manager Portal at any time. Registration or sign up to these services does not automatically guarantee access to bfinance content, materials or successful account creation on the Investment Manager Portal.
1.6 Cookies, Web Beacons and Other Similar Technologies
2. How We Use Your Data
How we use your personal data will depend on which bfinance services you use, how you use those services and whether you have opted-in or opted-out to our Pardot tracking cookie.
We use your email address to send you our newsletter on current thought leadership and market trends. We may also send you information on polls and surveys conducted by us and others through our services. You are not obligated to respond to polls or surveys, and you have choices about the information you provide. You may opt-out of our emails at any time.
The data collected by our Pardot tracking cookie helps us to understand areas of websites that you are most interested in and then use this information about you to personalise your website experience and provide you with more relevant email communications. This includes the help of automated systems.
2.2 Customer Support & Enquiries
We use information submitted via our contact form to help with your enquiry. This information will be shared with the department most relevant to your enquiry in order to provide you with the best possible answer.
We also use data collected by our Pardot tracking cookie to help you and fix problems. We use the data (which can include your communications) to investigate, respond to and resolve complaints and service issues, for example, website bugs.
2.3 Investment Manager Portal
We use the contact information collected on our Investment Manager Portal to notify you of current manager selection opportunities.
2.4 Job applications
All the information you provide through our job application form will only be used for the purpose of progressing your application, or to fulfil legal or regulatory requirements if necessary.
We will not share any of the information you provide during the recruitment process with any third parties for marketing purposes. The information you provide will be held securely by us and/or our data processors whether the information is in electronic or physical format. We will use the contact details you provide to us to contact you to progress your application. We will use the other information you provide to assess your suitability for the role you have applied for.
2.5 Security and Investigations
3. How We Share Information
3.2 Service Providers
We may use others to help us collect and make sense of this data (e.g., maintenance, analysis, audit, payments, fraud detection, marketing and development). They will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for any other purposes. Where appropriate, we will implement technical and organisational measures to protect a data subject's rights. This can include anonymising or pseudonymisation of data and restricting the amount of personal data processed, the access granted and/or any retention period. Where necessary we will audit third party providers to ensure that legal and regulatory requirements are being met.
3.3 Within bfinance Group Holdings and its subsidiaries
Our own internal policies set out very clear guidelines about who within the organisation your personal data can be shared with. We only ever share your personal data with bfinance employees if it is absolutely necessary. For example, if you submit an enquiry through our website, that information will be sent to the employees best suited to deal with that particular enquiry and no one else.
bfinance actively promote awareness and carries out training for employees in relation to the legal requirements relating to an individual’s personal information. We document current data processing activities on an ongoing basis, conducting data privacy impact assessments where necessary.
3.4 Cross-Border Data Transfers
The personal information we collect on our site may be sent to countries in which bfinance Group Holdings, its affiliates or subsidiaries maintain facilities. We may also store and process the information there.
Although the laws that protect personal information in those countries may differ from the laws where you live, we will take all steps necessary to ensure that your privacy and personal information is protected.
By using our site and giving your information to us, you consent to the transfer of the data outside of your country.
3.5 Legal Disclosures
In certain cases we may need to share your data when we believe it’s required by law or to help protect the rights and safety of you, us or others. It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you, (3) investigate and defend ourselves against any third-party claims or allegations, (4) protect the security or integrity of our Service (such as by sharing with companies facing similar threats); or (5) exercise or protect the rights and safety of our Visitors, Members of our Investment Manager Portal, personnel, or others.
We will attempt to notify individuals about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.
4. Data Retention and Lawful Bases for Processing
We have lawful bases to collect, use and share data about you. You have choices about our use of your data.
We will only collect and process personal data about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g. to deliver bfinance Services you have requested)) and “legitimate interests”.
Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. If you have any questions about the lawful bases upon which we collect and use your personal data, please contact us by email here DSAR@bfinance.com
We have outlined below our data retention schedules with regard to information that is submitted through our website.
4.1 Sign up to our newsletter
If you have signed-up to newsletters then we will continue to hold that information until you either opt-out or our email tracking indicates that you are no longer engaging with our emails. If you are no longer actively engaged in our emails then your data will be retained for a maximum of 3 years. After this term we may send you one final email asking you to re-consent before we stop emailing you.
4.2 White paper downloads
We may retain and process your personal data if you downloaded our white papers for up to 3 years. If you consented to us sending you our email newsletter at the time of submitting the white paper download form, then we will continue to process and retain this data until you either opt-out or are no longer actively engaged, in line with the newsletter sign-up data retention schedule above. After this term we may send you one final email asking you to re-consent before we stop emailing you.
4.3 Job application forms & recruitment
Where we have gathered information in relation to recruitment, your information will be kept by us for a maximum of 5 years in order to assess your suitability for future vacancies. After 5 years your personally identifiable information will be securely deleted.
4.4 Contact forms
Personally identifiable information entered through our websites contact forms is only kept as long as it is needed in order to progress and answer your enquiry or as long as we have an ongoing dialogue with you. After this it will be securely deleted.
4.5 Investment Manager Portal - impp.bfinance.com
We actively check the personally identifiable information in our Investment Manager Portal every 12 months. If we have reason to believe the contact information is no longer valid, then we will make attempts to update this information by sending you an email to check that you are still the appointed contact at your company. If this information changes, then we will securely delete any old personally identifiable information, reissue logon information and obtain consent from the new designated contact before entering additional information into our database.
5. Your Rights
5.1 Rights to Access and Control Your Personal Data
You can access or request us to delete your personal data. You have many choices about how your data is collected, used and shared. For personal data that we have about you:
Delete Data: You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you).
Change or Correct Data: You can ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate.
Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).
Right to Access and/or Take Your Data: You can ask us for a copy of your personal data and can ask for a copy of personal data you provided in machine readable form.
5.2 Your legal rights under the General Data Protection Regulation (GDPR)
As an individual you have additional rights under GDPR if you reside in the European Union (EU), European Economic Area (EEA), and Switzerland. These are:
Rights in relation to automated decision making and profiling: automated individual decision-making (making a decision solely by automated means without any human involvement); and profiling (automated processing of personal data to evaluate certain things about an individual). Profiling can be part of an automated decision-making process.
The right to file a complaint if you feel we have breached your rights in relation to your personal data: More information can be found here: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/
6. Other important information
bfinance is committed to protecting the security of your personal information. We monitor for and try to prevent security breaches. We implement security safeguards designed to protect your data, such as HTTPS and where possible abide by the “Privacy by Design” ethos. We regularly monitor our systems for possible vulnerabilities and attacks. However, we cannot warrant the security of any information that you send us. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. We use a variety of security technologies and procedures to help protect your personal information from unauthorised access, use, or disclosure.
For websites to which you login, it is your responsibility to ensure the security of your password and not to reveal this information to others.
6.2 Contact Information
36 Queen Street
We keep our privacy notice under regular review. This privacy notice was last updated on 17/05/2018.
Table of Contents
Or write to:
36 Queen Street
We keep our privacy notice under regular review. This privacy notice was last updated on 17/05/2018.