Privacy Policy and Legal Notices

Terms & Conditions of use

Please read the following terms and conditions carefully.

The following are the terms and conditions on which you may use the Waynflete Advisory website (the “Site”) and by accessing this Site you agree to be bound by them. If you do not accept these terms and conditions, please do not use this Site.

Responsibility

The Site is maintained by Waynflete Adivsory Limited (“Waynflete”) and is issued and approved in the UK by Waynflete. Waynflete is incorporated in England and Wales (company number 14952241, registered address at International House, 36-38 Cornhill, London, United Kingdom, EC3V 3NG).

Use of Site

The information provided on this Site is for personal use and information purposes only. Nothing on this Site should be construed as a solicitation or offer, or recommendation, to acquire or dispose of any investment or to engage in any other transaction, or to provide any investment advice or service.

The material on this Site is designed for use by professional investors in the UK only and is not directed to, nor intended for distribution or use by, any person or entity in any jurisdiction or country where the publication or availability of this Site or such distribution or use would be contrary to local law or regulation. If you choose to access information on this Site, it is your responsibility to comply with the applicable local, national or international laws and any use of this Site outside the UK is entirely at your own risk. For guidance relating to your specific situation, please contact your legal adviser.

Waynflete reserves the right to terminate your access to this Site, without notice, if Waynflete, in its sole discretion, believes that your continued use of the Site or any of its contents is in violation of any applicable law or is harmful to the interests of Waynflete.

Security & personal data

Please remember that Internet communications are not secure unless the data being sent is encrypted. Waynflete cannot accept any responsibility for the unauthorised access by a third party and/or the corruption of data being sent by individuals to Waynflete.

All information provided to Waynflete through this Site is used solely by Waynflete and its subsidiaries, affiliates, principals and employees and is not sold or provided to any other company or person.

By providing any personal data through this Site you agree that Waynflete and its subsidiaries, affiliates, principals and employees wherever located throughout the world may use, store or otherwise process such personal data. Such personal data may be processed by Waynflete and its subsidiaries, affiliates, principals and employees for the purposes of the evaluation of your potential financial needs and/or otherwise marketing financial services to you.

Cookies

Our website uses cookies to distinguish you from other users of our website. A cookie is a piece of data stored on a user’s hard drive containing information about the user.

The cookies we use are “analytical” cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the site when they are using it. This helps us to improve the way our website works.

The information below explains the cookies we use on our website(s) and why we use them:

Google Analytics cookies: we use these cookies to collect information about how visitors use our website, including details of the site where the visitor has come from and the total number of times a visitor has been to our website. We use the information to improve our website and enhance the experience of its visitors.

By using our website, you consent to our use of cookies as updated from time to time and the cookies we use will be stored on your device. However, you can choose to disable cookies by modifying the settings in your browser. You can find out how to do this, and find more information on cookies at: www.allaboutcookies.org.

If you do not accept our use of cookies as set out in these Terms and Conditions, please set your internet browser to reject cookies. This may impair your ability to use our website.

Accuracy of information

The information contained on the Site may have been taken from trade and statistical services and other sources which Waynflete deems reliable. However, Waynflete does not represent that such information is accurate or complete and it should not be relied upon as such. Any opinions expressed on the Site reflect our judgement at the date of issue and are subject to change without notice. Any pricing is indicative and does not, and is not intended to, constitute either an offer to buy or sell nor a representation that a purchase or sale can be affected at that price. Past performance is not indicative of future results.

Liability for contents

These ‘exclusion of liability’ provisions should be read carefully as they exclude or limit Waynflete’s legal liability in connection with your use of this Site.

Waynflete maintains this Site for the convenience of its users and for marketing purposes only. Although reasonable care has been taken to ensure that the information provided on this Site is reliable, no warranty or representation is given as to its accuracy or completeness and Waynflete hereby excludes, to the fullest extent permitted by applicable law, any and all (express or implied) representations and warranties of any kind including, without limitation, any warranty as to accuracy, availability, completeness or suitability for a particular purpose of the Site or any part of the content or materials.

Waynflete accepts no liability including (without limitation) in either contract, tort or negligence, to the fullest extent permitted by applicable law, for any loss, including (without limitation) direct, indirect, incidental, special or consequential, arising out of, or in connection with your use or inability to use the Site, or in connection with any error, omission, defect, computer virus or system failure, or for any loss of any profit, goodwill or reputation, even if expressly advised of the possibility of such loss or damages, arising out of or in connection with the access of, use of, performance of, browsing in or linking to other sites from this Site.

Waynflete reserves the right to modify, suspend or discontinue, temporarily or permanently, the Site or any part of it, with or without notice, at any time. You agree that Waynflete shall not be liable to you or to any third party for any such modification, suspension or discontinuance of the Site.

Advice

Opinions and any other content on the Site are provided by Waynflete for personal use and informational purposes only and are subject to change without notice.

Nothing contained on the Site constitutes investment, legal, tax or other advice and is not to be relied on in making an investment or other decision. You should obtain relevant and specific professional advice before making any investment decision.

Third party products & services

This Site may provide links to third party websites over which Waynflete has no control. Where Waynflete provides hypertext links to third party internet websites, such links are not an endorsement by Waynflete of any products or services in such websites.

You use such links entirely at your own risk and Waynflete accepts no responsibility or liability for the content, use or availability of such websites. Waynflete has not verified the truth or accuracy of any content of such websites.

This Site may also contain some material provided by third parties and Waynflete accepts no responsibility or liability for the accuracy of such material. No third party is permitted to link any other website to this Site without obtaining Waynflete’s prior written consent.

Governing law

English law governs these terms and conditions and you agree that the English Courts shall have exclusive jurisdiction to determine any matter or dispute in connection with or arising out of this Site and these terms and conditions.

© Waynflete Advisory Limited. All rights, save as expressly granted, are reserved. Reproduction in any form of any part of the contents of this Site without prior written consent is prohibited unless for personal use only.

WAYNFLETE ADVISORY LIMITED PRIVACY NOTICE

1. About us and this privacy policy and our role

This is the privacy policy for Waynflete Advisory Limited (“Waynflete”) and waynfleteadvisory.com (we, us and our). Our registered address is International House, 36-38 Cornhill, London, United Kingdom, EC3V 3NG. For the purposes of the General Data Protection Regulation (GDPR), we are the data controller of the personal data you submit to us regardless of the method of submission.

For the purposes of the General Data Protection Regulation (GDPR), Waynflete is also the Data Controller of the personal data you submit to us regardless of the method of submission.

We are committed to protecting the privacy and security of your personal information, in accordance with the applicable data protection laws, including the General Data Protection Regulation (GDPR). This privacy policy describes how we collect and use personal information about you during and after our relationship with you.

2. What information do we collect?

Personal information provided by you:

We may collect and process the following personal information about you (such as your name, date of birth, nationality, address, telephone number, email address, payment card details or bank account details and details concerning your financial position).

Any communications between us and our clients

Whether by telephone, email or otherwise. For example, to report a problem or to submit queries, concerns or comments regarding our services, investment or product updates or general comments.

Know Your Customer (KYC) documentation, which may include:
Copies of identity documents such as passports or driving licenses
Copies of address verification documents, such as utility bills or bank statements
Any other information needed to comply with our obligations under Anti Money Laundering law, which may include information on your source of funds and financial situation.

Personal information provided by third parties

Occasionally we may receive information about you from other sources (such as credit reference agencies), which we will add to the information we already hold about you in order to help us comply with our regulatory obligations.

In certain circumstances we may be required to carry out enhanced due diligence checks to comply with our obligations under the Money Laundering Regulations 2017. These enhanced checks may reveal information about criminal convictions or information about an individual’s political opinions and associations and/or other sensitive personal data. We will only collect and process such information to the extent necessary to comply with our regulatory obligations and in accordance with the applicable data protection laws.

3. Lawful basis and purposes of processing of your personal information

We will only use your personal information when the law allows us to, i.e. when it is necessary to:

perform our contractual obligations towards you: This is where the processing is necessary for a contract we have with you, or you have asked us to take specific steps before entering into a contract, such as determining suitability of a product or client for one or more investment projects. This lawful basis covers the following purposes:
Providing our services to you.
comply with our legal and regulatory obligations: We may be required to process or share your personal data in compliance with a legal obligation. In general, this will involve collecting information for KYC purposes, but we may also need to process your data in response to a request from the authorities, or when establishing, maintaining or defending legal claims.
pursue our legitimate interests (e.g. conducting our business in an efficient, compliant and profitable manner), and your interests and fundamental rights do not override these interests. Our legitimate interests include:
Improving our service
Providing you with client support
Providing you with information about further business opportunities offered by Waynflete.

We collect information about you so that we can:

provide our services to you, which includes verifying and maintaining an accurate record of our perspective and current clients.
carry out statistical and other analysis;
detect and prevent fraud;
conduct “know your customer” and anti-money laundering checks;
manage our relationship with you and your other advisers (if applicable);
improve our services;
manage our business, including for accounting and auditing purposes;
conduct our regular group reporting activities on the performance of our company, in the context of a business reorganisation or group restructure;
maintain our IT systems and manage hosting of our data;
deal with legal disputes involving you, your advisers (if applicable) or our suppliers or other parties whom we engage in connection with our services to you; and
comply with our reporting obligations

Some of the above grounds and purposes for processing will overlap and there may be several grounds which justify our use of your personal information.

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4. Will we disclose your personal information to anyone?

You acknowledge by use of this Site that we may share your personal information with third parties such as:

other companies within our group;
our agents and service providers, which includes our accountants;
credit reference agents to meet our anti-money laundering obligations;
regulators and also Her Majesty’s Revenue and Customs if obliged;
law enforcement agencies in connection with any investigation to help prevent unlawful activity; and

We require third parties to respect the security of your data and to treat it in accordance with the law. All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

5. Keeping your data secure

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. Third parties will only process your personal information on our instructions, and they are subject to a duty of confidentiality.

While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that are transferred via the internet. If you have any particular concerns about your information, please contact us (see ‘How can you contact us?’ below).

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

6. Transfers of your information out of the EEA

We take the security of your data very seriously, and all of your personal data will be kept according to strict safeguards and in compliance with GDPR. Your data will be stored securely on servers within the EEA and we will only store your data outside the EEA in the event that jurisdiction in question has been assessed as compliance with the GDPR.

7. Data retention

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. For example, in accordance with our legal and regulatory requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you.

8. Rights and duties

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please let us know if your personal information changes during your relationship with us.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a confirmation from us as to whether we process any of your personal information or not, and if this is the case, to receive a copy of such personal information and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information (often referred to as “the right to be forgotten”). This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it, or if we no longer need your data for our legitimate interests but we need to hold some of it for the purpose of legal proceedings.
Request the transfer of your personal information to another party.

If you would like to exercise any of the above rights, please:

email, call or write to us (see paragraph 9 below);
let us have proof of your identity and address (a copy of your driving license or passport and a recent utility or credit card bill). This is to allow us to verify your identity and prevent disclosure to unauthorised third parties; and
let us know the details of your request, for example by specifying the personal data you want to access, the information that is incorrect and the information with which it should be replaced.

Please note that if you request erasure, object to our processing of your personal data or request the restriction of our processing of your personal data we may not be able to provide our services to you.

9. Contact us or the ICO

Please contact us if you have any questions about this privacy policy or the information we hold about you.

If you wish to contact us, please send an email to [email protected]

You can also contact the Information Commissioner’s Office on 0303 123 1113.

10. Changes to the privacy policy

We may change this privacy policy from time to time. You can contact us if you wish to receive a copy of this policy occasionally.