1. Confidentiality:
We will keep your information confidential and only use it within our group (which means our affiliated companies, successors and assigns), and only transfer it to third parties in the manner described in the below section labelled “Use of third parties”, unless we are under a duty to disclose or share your personal data in order to comply with a court order or other legal or regulatory requirement.
2. Personal Data:
HANetf will use your personal data only for the purposes and in the manner set forth in this Privacy Policy which describes the steps taken to ensure our processing of your personal data is in compliance with the General Data Protection Regulation ((EU) 2016/679) ("GDPR") and any implementing legislation ("Data Protection Legislation").
How and why we collect personal data
HANetf will use your personal data only for the purposes and in the manner set forth in this Privacy Policy which describes the steps taken to ensure our processing of your personal data is in compliance with the General Data Protection Regulation ((EU) 2016/679) ("GDPR") and any implementing legislation ("Data Protection Legislation").
We will keep your information confidential and only use it within our group (which means our affiliated companies, successors and assigns), unless we are forced to share your personal data to comply with a court order or other legal or regulatory requirement.
The personal information we may collect might include your name, address, email address, company details and any other relevant information that may be included within correspondence. In addition, details of your visits to our website including (but not limited to) IP address, cookies, traffic data, location data, weblogs and other information related to what pages are accessed and when may be collected. Also, for legal reasons, in order to access our website, details of your investor type, and location will be collected, with such collection being carried out in compliance with the Privacy and Electronic Communications Regulations (“PECR”). This data would be collected to customise our users’ visits to our website.
If you are accessing sections of our website that are password protected or have entered the website through a link in an email, our website will identify you as an individual and may collect data including information about the pages you visit, the documents you download or other information to enhance and personalise your future interaction with our website.
Any information collected about you may be associated with other identifying information we hold.
HANetf will retain and process your personal data only when this is necessary to achieve our commercial or business objectives and to comply with our regulatory obligations. After careful consideration, HANetf has concluded the processing of personal data for the reasons mentioned shall be considered necessary, as there would not be another way of achieving the identified interest of the firm.
All information you provide to us is stored on secure servers. Information may be transferred, stored and processed by third parties. It may also be processed by staff operating outside the European Union (“EU”) who work for us or for one of our suppliers of services, such as data processors or providers of back up services. You should be aware that in territories outside the European Economic Area (“EEA”), laws and practices relating to the protection of personal data are likely to be different and, in some cases, may be weaker than those within the EEA. By submitting your personal data, you are agreeing to this transfer, storing or processing.
Such transfers outside the EU will only take place where either (i) the Commission has decided that such third country ensures an adequate level of protection; or (ii) we have provided appropriate safeguards, and on the condition that enforceable rights and effective legal remedies are available for you. If you use our services while you are outside the EU, your information may be transferred outside the EU in order to provide you with those services. By submitting your personal data, you agree to the potential transfer, storing and other processing described above. We will take all steps reasonably necessary to ensure that your personal data are treated securely and in accordance with this Privacy Policy.
3. Use of third parties
Communicating via the internet and sending information to you by other means necessarily involves your personal information passing through or being handled by third parties, but we do not sell or distribute without your permission your personal information to third parties for purposes of allowing them to market products and services to you.
We have also reviewed all key third party agreements where EU personal data is being processed to ensure they are GDPR compliant and that your rights described herein are being protected.
4. What safeguards we have in place
HANetf has security measures in place to protect the loss, misuse and alteration of the information under our control. As no data transmission over the internet can be guaranteed as 100% secure, we cannot ensure or warrant the security of any information you transmit to us and you transfer the data at your own risk. We endeavour to use appropriate security measures, including systems security, backups, business recovery and breach notification procedures, monitoring and testing procedures.
Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our website and accordingly any transmission is at your own risk. However, once we have received your information, we will use all appropriate procedures and security measures to try to prevent unauthorised access to or disclosure of your personal data.
5. What rights you have with regards to your personal data we process
You have the right to access your personal data and request a copy of the information held by us about you. You also have the right to ask for your information to be transferred to another organisation or to yourself. Where such requests are manifestly unfounded or excessive, we will inform you and we may charge a reasonable fee or refuse to respond to such a request.
You have the right to ask us not to process your personal data for marketing purposes. We will inform you if we intend to use your personal data for such purposes. You can exercise your right to prevent such processing by contacting us directly. You can also exercise the right and change your marketing preferences or restrict any specific uses of your personal data at any time by contacting us.
The accuracy of your information is important to us. We review the information we hold to ensure it is up to date and accurate. You have the right to correct any inaccuracies in the details we hold about you – if you change your email address or notice any other information we hold is inaccurate or out of date, please contact us. You have the right to obtain without undue delay the rectification of any inaccurate personal data concerning you. Your rights to access, rectify, erase or restrict your personal data stated above will be processed by HANetf usually within 30 days of receiving your request. However, HANetf may notify you within such timeframe of an increased time period to process your request and its reason. Where HANetf believes the request is unreasonable it shall notify you and refuse to process your request.
6. Complaints
If you have any questions regarding this Privacy Policy and our privacy practices you can contact us via email at [email protected] or in writing to Compliance, HANetf, City Tower, 40 Basinghall St, London EC2V 5DE.
7. Contact information
If you believe your personal data has been processed by HANetf in a way that does not comply with GDPR, you have the right to lodge a complaint with us directly [email protected] or with a supervisory authority.
If you believe HANetf did not take action on a request you have sent; or informed you without delay and at the latest within one month of receipt of the request of the reasons for not taking action and on the possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy, you have the right to lodge a complaint with a supervisory authority.
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