Introduction
We are committed to protecting your privacy and we take our responsibilities regarding the security of your information seriously. We have policies and procedures in place to establish the level of protection which you are entitled to expect. This Privacy Statement explains when, how and why we may collect personal information about you by which you are identifiable and your rights in relation to this.
Please note this is a Summary only of our full Privacy Notice which can be found here. Please ask us if you would like a hard copy.
Data Controller
In relation to any information we process about you when you visit this website, or as a client or prospective client, CS Managers Ltd is registered as a data controller with the Information Commissioner’s Office (the ICO), 45 Melville Street, Edinburgh EH3 7HL.
Who we are
CS Investment Managers is a trading name of CS Managers Ltd, 43 Charlotte Square, Edinburgh EH2 4HQ. CS Managers Ltd is authorised and regulated by the Financial Conduct Authority.
Where we use terms such as we, us and our in this Notice, we mean CS Managers Ltd and its trading name of CS Investment Managers.
What information do we collect about you?
We may store, use or otherwise process personal information about you which is provided by you or by someone with authority to do so on your behalf. This will include your contact details and other personal, identity, employment and financial data as necessary. We also receive information about you from third parties who provide an administration platform, the custodian, any SIPP provider and others who provide services to you (e.g. your solicitor, accountant or financial adviser).
When will we collect it?
We will collect this information, for example, when you apply for any of our services, become a client, or when you complete a contact form on this website. Other information may be obtained by us from publicly available sources e.g. Electoral Register and other organisations to verify your identity.
We will normally record and make notes of any telephone conversations you have with us. Your information may be contained in emails, letters, secure access portals, transaction reporting, valuations, telephone calls, visiting this website and other means.
How will we use the information about you and why?
We collect this information through your interaction with us. One of the key purposes for processing your information is to provide you with the services we offer, meet our contractual obligations and/or respond to enquiries you may wish to make. There are a number of legitimate business reasons we are entitled to rely upon as the basis for this processing, Where we rely on your consent to use your personal data, you have the right to withdraw that consent at any time. But this could affect our ability to deliver suitable services to you.
Will we share your information with third parties?
We will share your personal information with third parties. There are times when we are mandated by law to disclose your personal information to third parties (such as the Regulator). Additionally, we contract third parties to help us run our business and where we do so, we will also disclose your personal information to those third parties. Where we engage third parties to assist us to provide our services, we will always do so subject to appropriate contracts and safeguards being put in place. We will never sell, rent or trade your personal information to an outside company.
Will we send your information internationally?
Although we are based in the UK, sometimes your information may be sent to countries outside the UK and the EEA. If it is processed within Europe or other parts of the EEA, then your personal information will be protected by European data protection legislation. Some countries where your information is sent will offer different levels of protection. Where this is the case, we will take appropriate measures to ensure that your information is used in countries which have suitable safeguards in place or offer a level of protection similar to that which applies within the EEA.
How will we communicate with you?
We may communicate with you by post or email on a variety of topics relevant to the particular service you receive. These could include market commentary, events, news updates and similar. All recipients of communications of this type can opt-out and unsubscribe at any time by contacting our Privacy Team. From time to time, we may obtain your consent to send other material to you. When relying on the consent you can withdraw this at any time.
What are your rights under data protection laws?
Here is a summary of the rights that all individuals have under data protection laws. They do not apply in all circumstances. If you wish to exercise any of them, we will explain at that time if they apply or not.
- The right to be informed about our processing of your personal information;
- The right to have your personal information corrected if it is inaccurate and to have incomplete personal information completed;
- The right to object to the processing of your personal information;
- The right to restrict the processing of your personal information;
- The right to have your personal information erased;
- The right to request access to your personal information and to obtain information about how we process it;
- The right to move, copy or transfer a copy of the personal information you have provided to us.
There are additional rights in relation to automated decision-making which has a legal effect or otherwise significantly affect you. We do not undertake this activity.
To exercise your rights as set out above, please email our Privacy Team using the contact details below. There is no fee for making these requests. However, if your request is excessive or unfounded, we can charge a reasonable fee or refuse to comply with it.
You have the right to complain to the Information Commissioner’s Office which enforces data protection laws. For more information on this, please visit www.ico.org.uk
Do we do any monitoring which involves the processing of your personal information?
By monitoring, we mean any listening to, recording of, viewing of, intercepting of, or taking and keeping records (as the case may be) of calls, emails, text messages, social media messages, in-person face-to-face meetings and other communications.
We may monitor where permitted by law and we will do this where the law requires it. In particular, where we are required by the Financial Conduct Authority’s regulatory regime to record certain telephone lines or in-person meetings (as relevant) we will do so. It is standard practice at CS Investment Managers, that we will record all external calls for training, compliance, security and evidentiary purposes even where these calls fall outside of our regulatory obligations. This practice is noted within and forms part of our Terms of Business.
Other websites
Our website contains links to 3rd party websites. As such our privacy policy only applies to our website and not to any 3rd party links on the site.
Changes to our Privacy Policy
We keep this policy under regular review and we will place any updates on this website.
How to contact us
If you have any comments, queries or requests relating to this Statement, our Privacy Notice or the information we hold about you, please contact us:
A: Privacy Team
CS Investment Managers
43 Charlotte Square
Edinburgh
EH2 4HQ
Cookie Policy
A “cookie” is a small text file placed on your computer by websites you visit, and it helps the server to identify your computer, but not the individual. They are widely used to make websites work more efficiently for visitors, and to provide information to the owners of the website.
Our web server will log your Internet Protocol (IP) address or the IP address of your proxy server. It will not systematically track your domain name or your e-mail address for any purpose. We currently do not use any “cookie” technology on this site. If we add any cookies to this site in the future, we will change this notice to explain how such cookies are used.