Within Elkstone your personal information will be transmitted and stored in a protected environment. We keep our computers, files and building secure. We take measures reasonably designed to protect your personal information from loss, misuse, unauthorised access, disclosure, alteration or unlawful destruction.
We do not hold your personal information for longer than is necessary. We hold your personal information while you are our customer and for a period after that relationship ceases, as permitted by law e.g. 6 years under the Statute of Limitations Act 1957.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
LEGAL BASIS FOR USING YOUR PERSONAL INFORMATION
To use your personal information lawfully, we rely on one or more of the following legal bases:
• performance of a contract i.e. processing your personal information is necessary for us to provide you with products and services;
• we must process your personal information to comply with our legal obligations under MiFIR, AML law, Pensions law, etc.;
• our legitimate interests i.e. the interests of Harvest in conducting and managing our business when providing products and services; and
• your consent (which you may withdraw at any time).
Why we may need your consent and how you can withdraw it?
Sometimes we need your consent to use your personal information. If we process your personal information based on consent, you have the right to withdraw that consent at any time by contacting us directly at firstname.lastname@example.org or by selecting ‘unsubscribe’ link where relevant. With marketing for example, we need your consent to make you aware of products and services which may be of interest to you. New customers can opt-in to receive our marketing material.
Is your personal information transferred outside the EEA?
Your personal information is processed and stored within the European Economic Area (EEA). We may transfer your personal information to our service providers or other organisations outside of the EEA but only if they agree to act solely on our instructions and protect your personal information to the same standard that applies in the EEA (where relevant, a copy of EU Model Clauses are available on request).
Your legal rights
You have the right to:
• request a copy of your personal information;
• request that we correct or update your personal information;
• restrict our use of your personal information;
• object to our use of your personal information;
• request we transfer your personal information in digital form; and
• request we delete your personal information.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We generally do not charge you a fee when you request a copy of your personal information. However, if your request is deemed excessive or manifestly unfounded, we may choose to refuse your request or we may charge a reasonable fee to cover the additional administrative cost. We are obligated to act without undue delay, in most instances we will respond within one month of receipt of your request. This period may be extended by a further two months, we will notify you of any extension and the reason for the delay within one month of receipt of your request. Your right to obtain personal information can not adversely affect the rights and freedoms of others. Therefore, we can not provide personal information about other people without their consent.