DisclaimerTerms Of Use

PRIVACY


WWW.MALLOWSTREET.COM PRIVACY NOTICE

Overview

The website www.mallowstreet.com (“the Website”) is operated by Mallowstreet Limited (“Mallowstreet” or “we”) which is a private limited company incorporated in England and Wales. Mallowstreet Limited is a company authorised and regulated by the Financial Conduct Authority. This privacy policy explains how we use personal information collected from you in connection with the use of the Website. This Policy will automatically change from time to time, so please check back periodically.

The Website is designed as a search engine and information portal for the pensions, insurance and associated industries for use by experienced and authorised investment professionals and by product providers who offer financial products and services to the pensions and insurance industries (“Product Providers”). The content and facilities of the Website are made available to users who register with us and who are given permission to access the Website (“Subscribers”). The Website is designed to enable and assist Subscribers to learn about, research, compare and share information and views on financial products and services which may be relevant to their business or professional activities in the pensions, insurance and related financial industries, to allow Product Providers to represent and advertise their products and services and to enable Product Providers and Subscribers to communicate with each other in order to obtain further information and understanding of such products and services (“ the Services”).

This Privacy Policy will explain the following regarding use of the Website:

1. Personal Information collected
2. Data anonymization and aggregation
3. Purpose
4. Grounds for using your Personal Information
5. Data disclosure and data sharing
6. Data transfers
7. Retention
8. Updating and obtaining copies of your Personal Information
9. Direct Marketing and managing your preferences

10. Security

11. Our third-party use of "cookies" and "action tags."
12. You should carefully review privacy policies of any third-party sites accessible from the Website.
13. Contacting us about privacy questions or concerns.
14. Privacy Policy changes.
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1. Personal Information Collected

We collect and keep the information you provide to us in registering to use the Website including your name, contact details, employment details, professional details and profile information you provide to us. We may also collect information about you through on-line surveys and questionnaires, preference choices you make and information on your usage of the Website (the pages viewed, facilities used and so forth). This information may include the Uniform Resource Locator ("URL") of the website that you just came from, which URL you next go to, what browser you are using, and your Internet Protocol ("IP") address. A URL is the global address of documents and other resources on the World Wide Web. An IP address is an identifier for a computer or device on a Transmission Control Protocol/Internet Protocol ("TCP/IP") network, such as the World Wide Web. An IP address is a number that is automatically assigned to your computer whenever you are surfing the web, allowing web servers to locate, identify and serve information to your computer. We may also collect and keep personal information you provide to us in direct communications with us (by email or telephone). The foregoing information is kept as information about you and will be referred to in this Privacy Policy as “Personal Information”.
Subscribers are invited to contribute content to the Website, complete a profile page (which is available to the other members of the mallowstreet community) containing personal information as part of their account, participate in forum discussions and communicate with other Subscribers and with Product Providers (“Open Contributions”). We will collect and store copies of the Website and its content on a regular basis including records of all Open Contributions.

2. Data anonymization and aggregation

We monitor usage of the Website by Subscribers and collect and process statistical information on a non-personally identifiable basis about Subscribers, their profile, preferences and use of the Website. This includes the information which is otherwise Personal Information except that it is processed on an anonymous basis and cannot be linked to specific individuals or entities. On an aggregated basis, we collect anonymous data related to the pages, downloads and other content that is sampled, clicked on, streamed, searched for transferred from and downloaded (“Profile Data”). This data will not be subject to the relevant sections of this Privacy and Cookies Policy.


3. Purpose

Personal Information

Our main purposes in collecting and holding Personal Information from Subscribers are (i) to verify that each Subscriber is a suitable Subscriber for the Website and to ensure that only users at whom the Website is aimed are using the Website; (ii) to monitor and maintain the security of the Website and to protect the Website and other Subscribers and Product Providers against abuses; (iii) to meet our legal and regulatory obligations, to prevent the Website from being used for fraud and other unlawful activities; (iv) to enable us to communicate with you; and (v) to enable us to build up a picture of your preferences, the types of products, services, news, services and facilities which may be of interest to you and create a more personalised online experience for you, to enhance your experience and to tailor the Website to your preferences and usage. We may also share your Personal Information with third parties who provide services to us. Those third parties include authorised contractors, temporary employees and consultants and other companies working with us (collectively, "agents"). We will require our agents not to disclose or use your Personal Information for purposes other than to provide services to you or to Mallowstreet to process your Personal Information only in accordance with our instructions. Please refer to the section “Data disclosure and data sharing” in relation to other third parties who may collect information from you or with whom we may share your Personal Information.

Profile Data

We reserve the right to use and share Profile Data at our discretion. We may use Profile Data for any purpose but we intend to use it specifically to build a picture of the aggregate preferences, types of products, services, news and information which may be of interest to Subscribers, to process and make such information available on the Website, to Product Provides or advertisers or to any other person whether publicly or in confidence; to help formulate our marketing and business strategy, to help to improve the Website, for analysing and researching our business, customers and products; and to gather information about Subscribers’ usage of the Website and in order to enhance Subscribers’ experience by tailoring the Website to meet Subscribers’ needs.


Online Surveys and Polling

In order to improve our services, we may from time to time ask you to voluntarily complete surveys, which may be collected by an independent third party. Individual survey answers are confidential, although Profile Data is collected and disclosed to third parties. If you do not wish to participate in a survey, simply decline to participate when asked.

Newsletters, Promotional E-mails and Personalised On-line Advertisements

We and any Product Providers may wish to contact you through the messaging system on the Website to offer information on financial products and services, newsletters and other promotional communications. The purpose of the Website is to provide a forum for exchange of information and a facility for communication between Product Providers and Subscribers. Accordingly, we will ask you to indicate your consent to receiving unsolicited promotional communications from us, from Product Providers and other Subscribers. You may at any time advise us or any Product Provider or other Subscriber, through the messaging system on the Website or through any other means, that you do not wish to receive such promotional communications.

Contact Information and Third-Party Data

If you contact a Mallowstreet representative by telephone, e-mail or letter, we may keep a record of your correspondence or comments. If you report a problem with the Website, we may collect such information in a file specific to you. If you contact us through our feedback area or by calling one of our customer service representatives, we may ask for your name, e-mail address and other information in order to send you a reply. If other users or third parties send us correspondence about your activities on the Website, we may keep the information in a file specific to you. All such information will be held as Personal Information and will be used only for the purposes identified in this Privacy Policy.

Website Use

We also track Subscribers’ traffic patterns throughout their online session, including which pages, information and advertisements a Subscriber views while using the Website. We use your IP address to diagnose problems with our servers, software, to administer the Website and to gather demographic information.

Cookies and Action Tags/Web Beacons

We may use and allow others to use cookies, action tags or web beacons in the operation of the Website. To find out what cookies, action tags or web beacons are and how they are used, please see the section "Use of Cookies and Action Tags" below.

4. Grounds for using your Personal Information
We rely on the following legal grounds to process your Personal Information, namely:
• Performance of a contract – We may need to collect and use your Personal Information to enter into a contract with you or to perform a contract that you have with us (e.g. to deliver the Website services).
• Consent – Where required by applicable laws, we will rely on your consent for direct marketing.
• Legitimate interests – We may use your Personal Information for our legitimate business interests (which is not overridden by your data protection interests), to provide services and to improve our products and services.

5. Data disclosure and data sharing

Open Contributions

Open Contributions will be available to all Subscribers and Product Providers.

Product Providers
With your prior consent we may share your Personal Information with Product Providers with whom you communicate through the Website, in order to enable the Product Provider to keep the records required in order to comply with its legal and regulatory duties.

Other Parties Generally
We may provide Profile Data about users' traffic patterns, and related site information to third parties, but these statistics do not include any Personal Information that may be linked to specific Subscribers. We may disclose Personal Information to third parties if we believe that such disclosure is reasonably necessary to enforce or apply the Website terms of service or to protect the rights, property, and safety of Mallowstreet, the Website, other Subscribers or Product Providers or others. We may also share your Personal Information with third parties who provide services to us.

Marketing Partners, Co-Branded Services
We may run promotions for third-parties such as other service providers whose websites you may also visit. In some of those promotions, a window or frame containing the service provider's website may appear. Any time you access another website through a window, the personal information obtained through that site may be collected, used and disclosed by the operator of that website in accordance with that third-party's policies (if any). This Privacy Policy does not apply to information that you supply to those third parties.

Links and Banner Advertisements to Third-Party Sites
Please be aware that the Website may contain links to other sites on the Internet that are owned and operated by third parties. The information practices of those websites linking from or to the Website are not covered by this Privacy Policy. To find out more about what you need to be aware of in relation to such sites please see section “Review privacy policies of any third party sites accessible from Mallowstreet” below.

Advertisement & Content Servers, Advertisers, Image Servers and Website Analysis Agents
We may use Advertisement & Content Servers, Advertisers, Image Servers and Website Analysis agents to serve advertisements and graphics that Subscribers see on the Website more quickly, send promotional emails and help manage our internet business and marketing by measuring the effectiveness of our advertising and how Subscribers use the Website.

These third parties use their cookies' identification numbers and internal web site tracking features to serve advertisements on the Website and to collect aggregated information to create statistics about our Subscribers, traffic patterns, and related site information. In the event that our advertisement servers collect any Personal Information on our behalf, it will not be used by them or disclosed to any third parties. To find out more information about Advertisement & Content Servers, Advertisers, Image Servers and Website Analysis agents see the section “Use of Cookies and Action Tags” below.

Legal Proceedings and Law Enforcement
Occasionally Mallowstreet may be asked by regulators, law enforcement or judicial authorities to provide Personal Information on Subscribers. We will disclose such information upon receipt of a court order, subpoena, or request from a regulatory or law enforcement authority. Mallowstreet will co-operate fully with law enforcement agencies to identify those who use the Website for illegal activities. We reserve the right to report to law enforcement agencies any activities that we believe to be unlawful.

Sale of the business
We reserve the right to disclose and transfer your Personal Information in the event that Mallowstreet or the business activities relating to the operation of the Website are sold or transferred, in whole or in part to another person or entity.

6. Data Transfers
Your Personal Information may be transferred outside your own country. In particular, your Personal Information may be transferred to countries or territories outside the European Economic Area. Mallowstreet will seek to ensure your Personal Information is protected in those other countries or territories in accordance with applicable privacy law.

7. Retention

How long we keep information we collect about you depends on the type of information, as described in further detail below. After the relevant time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.

Account information: We retain your account information for as long as your account is active and a reasonable period thereafter in case you decide to re-activate the Services. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our Services. Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyze personal characteristics about you.

Information you share on the Services: If your account is deactivated or disabled, some of your information and the content you have provided will remain in order to allow your team members or other users to make full use of the Services. For example, we may continue to display content you provided unless you request for content to be deleted.

Managed accounts: If the Services are made available to you through an organization (e.g., your employer), we retain your information as long as required by the administrator of your account.

Marketing information: If you have elected to receive marketing emails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our Services, such as when you last opened an email from us. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.

8. Updating and obtaining copies of Your Personal Information

We encourage you to promptly inform us with any updates required to your profile or information when they change at usersupport@mallowstreet.com. You may ask to have the information on your account deleted or removed; however, because we "back up" the data stored on our systems, as a security measure, such prior information cannot be completely removed from our databases. As a result, although efforts will be made to ensure that data is not kept for longer than is necessary, you should not expect that all your Personal Information will be completely removed from our backed-up databases.

You may request from us a copy of any of your Personal Information we hold. You should contact us in writing to make such a request or if at any time you want to change your preferences about how we use or share Personal Information for marketing purposes. Please contact the data protection team at privacy@mallowstreet.com.

9. Direct Marketing and Managing your Preferences

We will not send you, or allow third parties to whom we provide your Personal Information, to send you e-mails or other promotional material in electronic form (including through the Website messaging system) unless you opt in as part of our services or if the e-mail or other promotion relates to products or services similar to those you ordered from us. You may advise us that you do not wish to receive such emails or promotional materials from us by following the “unsubscribe instructions” in any e-mail, or promotional material you receive from us, or by sending an e-mail to usersupport@mallowstreet.com. After doing so, if you have opted out of receiving all promotional emails you will not receive future promotional emails from us, unless you open a new account, or otherwise subsequently sign up to receive, such emails. Please Note: If you agree to receive e-mails or electronic messages through the Website messaging system from third party Product Providers, you will receive those communications directly from them, and information that you choose to disclose to them will be subject to their privacy policy. If you later decide that you no longer want to receive their e-mails, you will need to follow their own specific opt-out instructions. Opting out to usersupport@mallowstreet.com as described above will not opt you out of their promotional emails. You may also set your browser so that it will not accept "cookies" to prevent assignment from the advertisement server of a unique identifier; however, you may experience difficulty using the Website if you do so.

10. Security

We are committed to ensuring appropriate security for your Personal Information as required by the data protection legislation. Although absolute security cannot be guaranteed, the Website has in place measures to protect your Personal Information. So that you can send your details to us with confidence, all the information above is transmitted using SSL encryption.

Your Personal Information is kept on password protected, limited access servers. Wherever possible and applicable, Mallowstreet servers reside behind a corporate firewall that maintains controls on access to the system from both our internal network and the Internet. Access to your Personal Information is allowed only to staff that require such access and we require our staff to keep that information in confidence and to keep it secure. We require any third party that receives your Personal Information to maintain adequate technical and organisational measures to ensure the security of the information.

11. Mallowstreet and third-party use of "cookies" and "action tags."

A cookie is a small data text file, which a website stores on your computer's hard drive (if your Web browser permits) that can later be retrieved to identify you to the website operator. Cookies enable the sender to identify, authenticate and maintain information about the way visitors use websites. We may use cookies for example:
(a) to retain information for the duration of your visit so you can conveniently move between pages on the Website;
(b) to track the effectiveness of online advertising of the Website. If you come to the Website through a third-party advertisement or link, the third party may place its own cookie on your computer’s hard drive. Non-personalised information about how the website is used, for example, whether there are any return visits to the Website, and whether the visit or subsequent visits result in a catalogue request, may be used by us and/or the third party to measure the performance of the third-party advertising. We recommend you refer to the privacy policy of any third parties whose advertising directs you to the Website; and
(c) if you register your details with us, to gather and store information about how you use the Website each time you visit. This helps us build on ongoing picture of your needs and preferences so that we can tailor future visits to the Website according to your particular usage.

Cookies enable us to make your use of this website easier and bring you enhanced Website functions and services, enable the site to run more smoothly and help us to maintain a secure site. You will be given the opportunity to refuse to allow the use of cookies on your computer or the storage of or access to information stored on your computer for purposes of customisation or personalisation of the service. The "help" button on the menu bar of most browsers will tell you how to do this or how to have your browser automatically notify you when you receive a cookie so that you can decide whether to accept it. However, you will be unable to use the Website effectively without your browser being set to accept cookies.

Advertisement Server and Content Server Cookies: We may use an outside ad serving company or content server to display banner advertisements and other information on the Website or to serve promotional emails or personalised on-line advertisements. As part of their service, they place a separate cookie on your computer. Except for the entity that serves our promotional emails and personalised on-line advertisements, Mallowstreet does not provide third-party advertisement servers with any of your Personal Information. Mallowstreet and its third party advertisement servers do collect and use Profile Data which may include your computer’s IP address, browser type, the URLs from which you came, referring site's domain types (e.g., .com), operating system, the country, the server your computer is logged onto, where the servers that your computer is logged onto is located, the pages of the Website and products that Subscribers viewed during their visit, where an advertisement was placed on a specific Website page, the time and date particular advertisements were served, the post code associated with your server and whether you responded to a particular advertisement, and a receipt identifier.

Our third-party advertisement servers will occasionally use outside agents, whose computers will serve advertisements on the Website in the same manner and under the same conditions as described above. In addition, other ad serving companies or advertisers may place banner advertisements on the Website in the same manner as above, but accept that as disclosed in this Privacy Policy we do not disclose to them any Personal Information.
Image Server Cookies: As part of the advertisement-serving process, a third party may serve graphics upon the Website. In order to customise their service, they may also place a cookie upon your computer. You will be given the opportunity to refuse to allow the use of cookies on your computer for purposes of graphics serving or customisation. While Mallowstreet does not control their use of that cookie, no Personal Information is collected.
Website Analysis Agent Cookies: We may use a third party to analyse what our visitors find to be most interesting on the Website. To do that, they will place a cookie on your computer with a randomly assigned unique number in order to track the pages you view on the Website, along with other Profile Data. You will be given the opportunity to refuse to allow the use of cookies on your computer for the purpose of analysis.

Action Tags, Web Beacons and other Data Collection Methods: An action tag or a web-beacon (also known as a clear gif or a pixel tag) is a method used to track responses or actions by customers who view certain advertisements or other information on a website. Action tags are 1x1 pixel images embedded in a website page that are used to transparently collect information. Our advertisement server, content servers, affiliate program manager and website analysis agents may use action tags to count the number of times that visitors click on a particular banner ad or visit the pages of the Website and to provide information about what products are viewed. Without collecting any personal Information, they use that data to tell us (and other advertisers) which advertisements are the most effective on particular sites.

E-mail Distributor's Use of Action Tags: Our third-party e-mail distributor may also use action tags. They may, for example, keep track of when a promotional e-mail is opened and provide Mallowstreet with ongoing aggregated reports of how many customers have responded. We share with them anonymously, Profile Data about Subscribers who have received a promotional e-mail or other targeted promotional campaign. They use the information for the purpose of targeting future campaigns and upgrading Subscriber information used in reporting statistics. For this purpose, we and our third-party e-mail distributor note some of the pages you visit on the Website through the use of action tags.

12. You should carefully review privacy policies of any third-party sites accessible from the Website.
Other websites accessible through the Website (including those of Product Providers) have their own privacy policies and data collection, use and disclosure practices. Please consult each website's privacy policy. Mallowstreet is not responsible for the policies or practices of Product Providers or other third parties. These other sites may send their own cookies to users, collect data, or solicit personal information. Additionally, other companies that place advertising on the Website may collect information about you when you view or click on their advertising through the use of cookies. We cannot control this collection of information. You should contact these advertisers directly if you have any questions about their use of the information that they collect.

On behalf of various third parties, Mallowstreet may provide links to third-party websites. If you click on a sponsored link or banner advertisement, a "window" or "frame" containing a third-party's website may appear in the foreground with the Website remaining in the background. Any time that you move to a window shown in the Website, you access another website and personal information obtained through that site is collected, used and disclosed by the operator of that site in accordance with that website’s policy (if any). This Privacy Policy does not apply to information that you supply to those third parties. If you are unsure as to whose privacy policy applies, please contact us by sending an email to: privacy@mallowstreet.com.

13. Contacting Mallowstreet Ltd about privacy questions or concerns.

If you have any questions about this Privacy Policy, the practices of this Website, or your dealings with this site, please contact the data protection team at Mallowstreet Ltd by sending an email to: privacy@mallowstreet.com
Attn: Privacy Compliance Officer


14. Privacy Policy changes.

This Privacy Policy was last changed on 08/05/2018. We may change, modify, add or remove portions of this Privacy Policy at any time, and any changes will become effective immediately upon being posted unless we tell you otherwise.
In the period leading up to the implementation of the General Data Protection Regulation the ICO is regularly updating their guidance, so we there may be some changes to this policy in the coming months.