Citywire

YOUR INFORMATION AND HOW WE USE IT

Thank you for visiting the Citywire website and completing any registration forms and questionnaires including but not limited to the Citywire NMA Survey and for providing us with details relating to you and your organisation.

We would like to take this opportunity to explain exactly why we gather this data, how we will use it and where it will be appearing.

When you Register and use the Sites, we will ask you to provide certain Data, such as your contact details and demographic information. We will store this Data and use it to contact you, provide you with details of Services and otherwise for the normal use and improvement of the Sites, unless you have asked us not to do so by modifying your MyCitywire profile anytime thereafter.
We may also use the Data you provide us in response to surveys or provided during Registration to aggregate user profiles and to make you aware of relevant events and content by post, phone, email and SMS.
To enable us to monitor and improve the Sites, we may gather certain information about you when you use the Sites. This includes details of your operating system, browser version, domain name and IP address, and the details of the website you referred from.
The data relating to your use of the website, including a summary of the factsheets you have downloaded, the pages you have viewed, and any articles sent via the Email a Friend facility, will also be collected. Please note that Citywire may provide this data to third parties, including the fund manager's group of the manager's whose factsheets you have downloaded.
We may use cookies to store information such as your User ID and your session identifiers to enable us to identify whether you are Registered on to the Sites and, if so, to shortcut your access to the Sites. We will only read cookies from your cookie file placed there through your web browser's interaction with the Sites. Please refer to documentation provided by your browser for more information on how disabling your cookies and withholding information outlined in paragraph 3 will affect your operability with our Sites. We cannot guarantee full operability of our Sites if you disable your cookies.
We maintain a record of all the articles that have been sent via the Email a Friend facility on the Sites. We will keep a record of the email addresses that articles are sent to and from. We keep a record of the content and comments sent by Registered Users and Visitors using the Email a Friend facility for research purposes and from time to time we may publish on our Sites some of the comments made by Registered Users and Visitors in their emails. These comments will be ANONYMISED and will not be associated to any individual sender or recipient. You accept that by using the Email a Friend facility that your comments may be published, anonymously, on our Sites.
The data relating to you and your organisation and some, or all, of the information you have provided may appear: in Citywire's regular printed publications, such as New Model Adviser, Citywire Global and Citywire Wealth Manager, on online websites such as www.nmablog.com or www.citywire.co.uk, and in Citywire's IFA factsheets which may be available online and in print. A comprehensive list of publications and online websites can be obtained by emailing Citywire at privacy@citywire.co.uk.
Citywire may licence this data to companies/institutions with a keen interest in asset management including, for instance, fund management groups and life companies. We will impose tight restrictions on how our licensees use the data we provide.
We are not responsible for the data policies, procedures or content of any other website that are linked to our Sites.
We may supplement the information that you provide us with information we receive from third parties.
To ensure that our records are up-to-date, we may contact you from time to time to check that the information you have provided is still accurate. If, at any stage, any of your details change and you would like us to reflect that change, please email the details of any changes privacy@citywire.co.uk.
Where appropriate we will contact you or a representative from your fund management group from time to time to ensure that the information we hold remains accurate. If, however, any of the details you provided change and you would like us to reflect that change, please contact our Customer Services Department 020 7840 5100 or at privacy@citywire.co.uk and we will be happy to update your details.
We have certain responsibilities under legislation to verify the identity of Registered Users and users and may need to make certain enquiries and obtain certain information from you for that purpose. By using the Sites you confirm that all information you supply will be accurate and that we may pass on such information, as we consider necessary, to comply with any reporting requirements.
You agree that we may disclose to the FSA, to any other regulatory authority to which we are subject and to any investment exchange on which we may deal or to its related clearing house (or to investigators, inspectors or agents appointed by them), or to any person empowered to require such information by or under any legal enactment, any information they may request or require relating to you or, if relevant, any of your clients.

ACCESS TO YOUR INFORMATION

You have the right to receive information about the personal information we hold on you. You can obtain a copy of the information we hold about you by sending an email to privacy@citywire.co.uk or contacting us on 020 7840 2250. If you are concerned that any of the information we hold on you is incorrect, please contact us at privacy@citywire.co.uk.
If you have any questions about our privacy policy, please contact us at privacy@citywire.co.uk.
If you would like to request a comprehensive list of our current websites please contact us at privacy@citywire.co.uk.

INFORMATION SECURITY

We endeavour to take all reasonable steps to protect your Data, including the use of encryption technology, but cannot guarantee the security of any Data you disclose online. You accept the inherent security implications of dealing on-line over the Internet and will not hold us responsible for any breach of security unless we have been negligent or in wilful default.

INDIVIDUAL CHOICE

You can change your personal information preferences and/or details at any time. As a registered user you can access your preferences by logging on to www.citywire.co.uk using your username (email address) and password. You may unsubscribe to any/all lists by sending an email request to privacy@citywire.co.uk.
You will ALWAYS be given a straightforward way to opt out from our direct marketing each time you receive a communication from us or one of our advertising partners.

ⁱ _{Consent is defined in the European Data Protection Directive 95/46/EC as 'the data subject's consent' shall mean any freely given specific and informed indication of his wishes by which the data subject signifies his agreement to personal data relating to him being processed}

ⁱⁱ _{'Data Protection Good Practice Note: Electronic mail marketing': version 2.0}

ⁱⁱⁱ _{Article 29 Working Party Opinion 5/2004 on unsolicited communications for marketing purposes}

_{under Article 13 of Directive 2002/58/EC. States ...'Implied consent to receive such mails is not compatible with the definition of consent of Directive 95/46/EC and in particular with the requirement of consent being the indication of someone's wishes, including where this would be done 'unless opposition is made' (opt-out). Similarly, pre-ticked boxes, e.g., on websites are not compatible with the definition of the Directive either.'}

^iv _{Data Protection Act 1998 Section 11 Right to not have personal data used for the purpose of direct marketing.}