[Policy revised 25th May 2018 and reviewed annually]
Institutional Protection Services Ltd (IP) is a global class and group investor action specialist, providing worldwide shareholder action and settlement monitoring and claims recovery services for institutional investors around the world. IP deals in the management of complex and often data intensive matters. Although, most of the data IP processes is securities and financial related, we do on occasion encounter and process personal data as well. Due to the global nature of its activities IP may transfer certain items of personal data between members of the European Union and non-EEA countries.
IP understands that your privacy is important to you and that you care about how your personal information is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and our obligations under the law.
This Policy applies to our use of any and all data collected by us in relation to your use of Our Site. Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Account” means an account required to access and/or use certain areas and features of Our Site;
“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 11, below;]
“Our Site” means this website, www.institutionalprotection.com and its publicly facing sub-domains;
“UK and EU Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and]
“We/Us/Our” means Institutional Protection Services Ltd, a limited company registered in England under company number 5247486, whose registered address is 3rd Floor, 1-3 Staple Inn, London WC1V 7QH and whose main trading address is Third Floor, 1-3 Staple Inn, London WC1V 7QH.
2. Information About Us
2.1 Our Site, www.institutionalprotection.com and any sub-domains, is owned and operated by Institutional Protection Services Ltd, a limited company registered in England under Company Number 5247486 whose registered address is 1-3 Staple Inn, London WC1V 7QH. Our VAT number is GB 849324503.
2.2 IP is committed to respecting the privacy of individuals and is registered with the Information Commissioner’s Office in the United Kingdom for data protection purposes.
3. Scope – What Does This Policy Cover?
This Privacy Policy applies only to your use of Our Site. It does not extend to any third party websites that are linked to from Our Site (whether We provide those links or whether they are shared by other users). We have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
4. What Data Do We Collect?
Some data will be collected automatically by Our Site. For further details, please see section 11 on Our use of Cookies. Depending upon your use of certain areas of Our Site, we may collect some or all of the following data:
4.1 Organisation name
4.2 Country
4.3 Email address
4.4 Username
4.5 IP address (automatically collected with form submissions)
4.6 Source URL (automatically collected with form submissions)
5. How Do We Use Your Data?
5.1 All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see section 6, below.
5.2 We use your data to provide access to certain areas of Our Site.
5.3 Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
a) you have given consent to the processing of your personal data for one or more specific purposes;
b) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
c) processing is necessary for compliance with a legal obligation to which we are subject;
d) processing is necessary to protect the vital interests of you or of another natural person;
e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
6. How and Where Do We Store Your Data?
6.1 Your data will only be stored in Our Site and used solely for the operation of Our Site and will be automatically deleted after 30 days.
6.2 Your data will only be stored within the United Kingdom.
6.3 Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site.
6.4 Steps We take to secure and protect your data include:
6.4.1 The website uses SSL ensuring your data is not exposed during form submissions.
6.5 Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.
7. Do We Share Your Data?
In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us
8. What Happens If Our Business Changes Hands?
We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Data provided by users will, where it is relevant to any part of Our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the data for the purposes for which it was originally collected by Us. In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.
9. Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it.
9.1 You may access certain areas of Our Site without providing any data at all. However, to use authenticated areas available on Our Site you may be required to submit or allow for the collection of certain data.
9.2 You may restrict your internet browser’s use of Cookies. For more information, see section 11.
9.3 You may withdraw your consent for Us to use your personal data as set out in section 4 at any time by contacting Us using the details set out in section 13, and We will delete Your data from Our systems. However, you acknowledge this may limit Our ability to provide you with access to certain areas of Our Site.
10. How Can You Access Your Data?
You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at info@institutionalprotection.com or using the contact details below in section 14.
11. What Cookies Do We Use and What For?
11.1 Cookies are small, plain text files which are downloaded to a device when you access websites. Cookies can be used for a variety of purposes:
11.2 Certain features of Our Site depend on Cookies to function. UK and EU Cookie Law deem these Cookies to be “strictly necessary” as they are “session cookies” and provided purely for security. Your consent will not be sought to place these Cookies. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 11.4, but please be aware that this will block access to parts of Our Site. We have taken great care to ensure that your privacy is not at risk by allowing them.
11.3 You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
11.4 You can choose to delete Cookies at any time however you may lose any information that enables you to access certain areas of Our Site.
11.5 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
12. Summary of Your Rights under GDPR
Under the GDPR, you have:
12.1 the right to request access to, deletion of or correction of, your personal data held by Us;
12.2 the right to complain to a supervisory authority;
12.3 be informed of what data processing is taking place;
12.4 the right to restrict processing;
12.5 the right to data portability;
12.6 object to processing of your personal data;
12.7 rights with respect to automated decision-making and profiling. To enforce any of the foregoing rights or if you have any other questions about Our Site or this Privacy Policy, please contact Us using the details set out in section 15 below.
13. How do we protect your data when it is transferred outside the EEA?
IP complies with the rules in applicable data protection legislation governing the transfer of your personal information from countries in the European Economic Area (EEA) to countries outside the EEA. We may sometimes transfer your personal information to a country outside the EEA but before doing so we will take steps to ensure that your personal information is only transferred in accordance with applicable data protection legislation.
14. Contacting Us
If you have any questions about Our Site or this Privacy Policy, please contact Us by email at info@institutionalprotection.com by telephone on 0203 388 0310, or by post at Institutional Protection Services Ltd, Third Floor, 1-3 Staple Inn, London WC1V 7QH. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 10, above).
15. Changes to Our Privacy Policy
We may change this Privacy Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.