We want to make your online experience satisfying and safe. Our aim is to safeguard the privacy and security of your personal information whilst providing a personalised service that meets your individual preference and needs. At all times we will comply with the prevailing laws and regulations governing confidentiality data protection and security of information.
In this policy the words we, us and our always mean Computershare Investor Services Plc.
What personal information do we collect?
When we say personal information, we mean any information that is about you or which can help identify you.
We may collect your personal information in a number of ways. You may provide personal information to us directly or we may collect your personal information from third parties.
Information you provide to us
You may provide personal information to us when you contact us. This could be by email, letter, phone, or when you submit personal information online. Depending on the reason you are contacting us, the personal information we collect may include your name, date of birth, nationality, national ID reference, tax self-certification, contact details (such as residential address, correspondence address, email address), employment details and bank account details.
Other information we collect
We may also receive your personal information from other companies. For example:
- When we provide services to you as a company shareholder, that company may provide us with your name, contact details, shareholding data, and other personal information.
- If you are a participant in a company share plan, your employer may provide us with your name, date of birth, contact details, identity information, share entitlement data, compensation and/or payroll information, and other personal information.
How do we use your personal information?
We use your personal information in the following ways:
- To deal with requests you send us.
- To respond to your queries.
- To provide you services and to enable us to provide services to share issuers.
- To provide you updates on changes to our policies or terms and conditions.
- To help us improve our services.
- To analyse how people use our websites.
- For trend analysis to help us develop and improve our products and services.
- For profiling purposes to help us ensure that we provide you with the right information and offer you relevant services.
- If you agree, to contact you about other services and products we think may interest you.
- To comply with our legal and regulatory obligations, for example, transaction reporting under rules imposed by the Financial Conduct Authority.
- To deal with any complaints or legal claims.
Depending on the services we provide, we may also use your personal information for the following purposes:
- To maintain your account.
- To carry out your instructions in relation to your holdings, for instance to sell or transfer shares, or to vote and receive dividends if you hold a share plan account.
- To keep records of your holdings and any transactions that we facilitate on your behalf.
- To inform you of your rights as a shareholder (or other security holder).
- To tell you about other services that you may use as a shareholder (or other security holder).
What is our legal reason for processing your personal information?
The legal bases for us processing your personal information are that:
- It is necessary for us to process your personal information for us to perform our obligations under either a contract you have with us, or to take steps at your request before entering a contract with you or a contract we have with your employer or ex-employer.
- It is necessary for us to comply with a legal obligation to which we are subject.
- You have given consent to processing for one or more specific purposes.
- It is necessary for the purposes of legitimate interests pursued by us or by a third party, and those interests are not overridden by your interests or your fundamental rights and freedoms.
How do we share your personal information?
We share your personal information with other companies in a number of ways. This section provides details of the type of companies with which we may share your personal information and for what purposes.
How we share your personal information to provide you with services
We may share your personal information with other companies to help us deliver services as follows:
- Other Computershare group companies who help us administer our services.
- Non-Computershare companies who help us provide services to you, including stockbrokers or market makers who execute trades at our instruction on your behalf.
- Non-Computershare companies who we appoint as custodian to provide safe custody of assets on your behalf.
- Non-Computershare companies who help us with administrative services, including mailing services and IT services.
- Non-Computershare companies who help us with marketing activities, where you have provided consent to this.
- Brokers you use in obtaining our services or to whom we transfer securities on your behalf.
- A global payment service provider, to enable global payments to be made (if you use global payment services).
- An appointed tax agent to facilitate the calculation of tax (if you use tax services or your employer or ex-employer instructs us to send information to their appointed tax agent as part of the services they provide to you).
- A savings carrier to support the provision and administration of your savings account (if you use our savings services in connection with participation in certain types of company share plan).
Where we share your personal information with other companies to provide services to you, we ensure they have adequate safeguards to protect your personal information.
Data sharing with companies in which you have a holding
- We will share information about your holdings, and any dealings with them, with any person acting as the Relevant Company's registrar or transfer agent so they can maintain the relevant share dealing register.
- If you receive vested share account or share plan account services, or other services related to share plans, we may share your personal information with the Relevant Company, a nominee or trustee to facilitate the provision of the vested share account or share plan account service and/or administration of share plan(s) as applicable.
- If you receive nominee services from us, we will provide your information to the Relevant Company to facilitate the provision of the nominee account. This is so that the Relevant Company can inform you of your rights as a shareholder and keep you up-to-date on corporate matters.
Other data sharing
We will also share your personal information in the following circumstances:
- Where we need to do so to comply with our legal or regulatory obligations (which may include sharing information with regulators).
- In an effort to trace you if we lose contact with you.
- Where necessary to protect or defend our legal rights or the legal rights of another company or person.
- If our business, or any part of it, is transferred or sold, we will transfer your personal information to the company taking over our role, which could include a purchaser or the provider replacing us.
We will never sell your information to anybody for unsolicited marketing.
How long do we keep your personal information for?
We keep your personal information for as long as we need to for the purposes for which it was collected or (if longer) for any period for which we are required to keep personal information to comply with our legal and regulatory requirements.
Do we transfer your personal data overseas?
We may administer accounts and provide you with some services through another member of the Computershare group, or another company which is based in a country where data protection laws and standards differ from those in your home jurisdiction, including India, Australia, and the United States. If you are in Europe this means we may send your personal information to countries outside the European Economic Area.
Where we send your personal information to another country, we will always ensure adequate measures are in place to safeguard it and to ensure you can exercise your rights effectively. If you would like more information about transfers to other countries and the ways in which we protect your personal information, please contact our Data Protection Officer by emailing firstname.lastname@example.org.
Accessing your information
You may ask for a copy of the personal information we hold about you by writing to us at your nearest office. There may be a small charge for this service.
Correcting your information
We try to ensure all of your personal information is accurate. If you find any inaccuracies or if your details change, please notify us promptly and we will correct them.
Erasing or restricting use of your information
You may ask us to erase or restrict use of your personal information. If you do, we will comply with your request unless there is a legal reason for us not to (for example, if a law says we must retain records of share dealing for a fixed period and to do so we must retain your personal information, or if it is necessary for us to retain the personal information for the purpose of performing a contract with a share issuer).
Where the legal basis for us processing your personal information is that you have given your consent to that processing, you may withdraw your consent at any time. If you do so we will stop processing your personal data promptly.
Where you have provided consent for us to provide you with marketing information, you can change your preferences in relation to marketing at any time by contacting us at email@example.com.
If you have any complaints about the way we use your personal information please contact our Data Protection Officer who will try to resolve the issue. If we cannot resolve any issue, you have the right to complain to the data protection authority in your country. If you need more information about how to contact your local data protection authority please let us know by contacting our Data Protection Officer.
This Statement only applies to this website and does not apply to any websites from which you may have linked to this website or to any website to which you may link from this website.