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1. Who are Link Asset Services and Link Market Services?

Link Asset Services (“Link”) is a trading name of companies (including Link Market Services Limited and Link Market Services Trustees Limited in the UK and Link Registrars Limited and Link CTI Limited in Ireland) which offer a range of services, principally shareholder, treasury management, banking, debt, fund and corporate administration services. Please refer to the “Legal and Regulatory Status” page on the Link Asset Services website (https://www.linkassetservices.com/) for more details on the trading companies in the Link Asset Services division.  All of the companies are wholly owned subsidiaries of Link Administration Holdings Limited (“Link Group”). For more information on Link Group, please visit www.linkgroup.com.

Link Market Services is a trading name of Link Market Services Limited and Link Market Services Trustees Limited. Company details of each are specified in the ‘Legal statement’ page on this website (https://www.signalshares.com).

2. What is this Privacy Notice about?

At Link we collect personal information about you and are committed to protecting this information and your privacy. Set out below is an explanation of how we use, collect and safeguard your personal information. This Privacy Notice applies where any company within Link, and in particular, Link Market Services Limited, Link Market Services Trustees Limited, Link Registrars Limited, Link CTI Limited and each of their subsidiaries receives personal data through this website.

Where you apply to receive a specific service from us, such as our dividend reinvestment plan service, corporate sponsored nominee service and share dealing service, we may collect personal information from you in addition to the personal information collected in accordance with this Privacy Notice.  Details of such additional personal information that we collect, and the manner in which we use, collect and safeguard such additional personal information  will be set out in the terms and conditions and/or the privacy notice made available to you in relation to such specific service.

3. What personal information do we collect and where do we collect this from?

The principles of data protection are that only sufficient personal data should be collected and processed as is necessary for the purpose.  Link will collect and use only as much personal data from you as is necessary to be able to provide you with the products and services you have requested from us. The information we collect depends on the nature of our relationship with you.

As part of your use of our website you have the option on certain pages within this site to submit personal information to us by email, online enquiry or quotation forms. Depending on the services, products or information you request from us, where we are the data controller of your personal information, we may ask you to provide or may process the following personal information from you as a result of your use of this website, when you complete the appropriate forms or when you correspond with us:

  • contact details such as your name, address, email address and telephone number;
  • your date of birth, nationality and national client identifier information, national insurance number, passport details, tax identification number and driving licence details;
  • your bank account details or other payment or financial information;
  • information on your current shareholdings or other products including details of any other persons included in such holdings or products;
  • your shareholder reference number (IVC);
  • a record of any correspondence you have with us, including certain telephone calls which we may be legally required to record (but we will inform you at the beginning of the telephone conversation if the call is recorded).
  • website security questions and answers;
  • your website user name combined with your passwords;
  • online identifiers including IP address and cookies and information obtained through our use of cookies (you can find out more about this in our cookies policy below); and
  • your marketing preferences.

We collect personal information about you from things you tell us yourself and from things we ask other people or organisations to share with us. Things you tell us could come from conversations we have on the phone, what you’ve written on a form or if you send us an email. We might also collect information about you from other people and organisations, such as the Financial Conduct Authority or by checking databases like the electoral register. Please see below for a list of some of the ways we collect your personal information.

We collect personal information directly from you:

  • via application and various event registration forms;
  • through feedback forms and other forums;
  • when you purchase any of our products or services;
  • when you fill out a survey, or vote in a poll on our website;
  • via our telephone calls with you, which may be recorded;
  • when you provide your details to us either online or offline;
  • when you send an email; and
  • via cookies, which you can find out more about in the cookies policy on our website.

Depending on the nature of our relationship with you, we may also collect your personal information from a number of different sources including:

  • through companies which validate identity for financial crime purposes using tools such as the electoral register (this is not a credit check and does not leave a footprint on your digital record, but a record of the search may be retained by us);
  • from third party registers maintained by regulators such as the Financial Conduct Authority;
  • through business interactions between your company and Link Asset Services;
  • from your financial advisor; and
  • from family members if you become incapacitated or unable to provide information relevant to the product or service we provide to you.

If you are interested in attending our events, we may collect personal information such as your name, contact details and any dietary preferences as well as your consent to send you information about our products and services. Depending on our relationship with you, in certain limited circumstances we may request or receive sensitive personal information about you, such as details about your health if you require correspondence in braille, or your health or religion if you attend our events and have certain dietary preferences.

4. Why do we collect your information?

This is dependent upon the nature of the relationship we have with you:

  • if you are a client, we use your personal information to administer your product;
  • if you are a candidate for a job, we use your personal information as part of our recruitment process; and
  • if you are viewing our website, we may use your personal information contained in cookies.

We collect this information in order for you to use our website and to provide any services to you.

5. The legal basis for our processing of your data

We will collect and use your information only if we are able to satisfy one of the lawful bases for processing set out in the data protection laws (ensuring ‘lawfulness of processing’).

  • Processing may be  necessary to provide the product or service you have requested and for the performance of our contract with you in relation to such service, for example, if you wish to receive one of our services such as our corporate sponsored nominee service, dividend reinvestment plan and share dealing service, we will require some personal information including your name, address, date of birth and bank account details in order to assess your request or application, set you up within the service, administer and provide the service to you, handle any changes to your data, make payments to you and communicate to you.
  • Processing may be necessary for our legitimate interests, for example, to provide you with appropriate information and guidance so you are aware of the options that will help you get the best outcome from your service, to provide you with information about our products or events that we hold, to develop new products and services, to conduct research and collate information to improve the products and services we offer.
  • Processing may be necessary for us to meet our legal or regulatory obligations, for example, to tell you about changes to our terms and conditions or where a regulator, such as the Financial Conduct Authority, requires us to maintain certain records of any dealings with you.

In the circumstances detailed above, if you do not provide the required information, we may be unable to provide the relevant service to you, process your payment requests or interact with you for normal business purposes.

  • Processing may be necessary for reasons of public interest, for example, where we need to use your personal information to carry out anti-money laundering checks or to detect, prevent or investigate fraud.
  • Processing may be necessary for us to meet our legal obligations where we need to use your personal information to establish, exercise or defend our legal rights, for example, when we need to consult a solicitor or manage any legal claims, or where we want to pursue any legal claims ourselves.
  • Processing may be necessary if it is in the legitimate interests of a third party, for example, sharing information with your employer company in relation to the dealing of shares that have vested from an employer provided employee share plan.

Where the processing is in our legitimate interests or those of a third party, we will always conduct an assessment to ensure that this use of your personal information is not excessive or unnecessary or otherwise more intrusive than it needs to be.

In addition, we are required by law to obtain “know your client” information in relation to some of our services (as detailed in the specific terms and conditions for such services) and this includes certain personal information.

We will usually only ask for your consent in relation to processing your Special Category information (such as health data), or when providing marketing information to you (including information about other products and services) where we do not yet have a relationship with you. This will be made clear when you provide your personal information. If we ask for your consent we will explain why it is necessary.

6. How do we use your personal information?

Why we need your personal informationPersonal information we may process shall include, but shall not be limited to, the types of information set out belowLawful processing basis
To assess any application you make to participate in any service we provide (including your tax domicile status where required)
Contact details such as your name, address, email address and telephone number;

your date of birth, nationality and national client identifier information, national insurance number, passport details, tax identification number and driving licence details; and

your bank account details or other payment or financial information.

Similar information for other individuals included in your application form
To provide you with the service that you have applied for (contract) 
To facilitate your use of our website and to provide you with the services, products, and/or information you request from usContact details such as your name, address, email address and telephone number;

your date of birth, nationality and national client identifier information, national insurance number, passport details, tax identification number and driving licence details;

your bank account details or other payment or financial information;

information on your current shareholdings or other products including details of any other persons included in such holdings or products;

your shareholder reference number (IVC);

a record of any correspondence you have with us, including certain telephone calls which we may be legally required to record (but we will inform you at the beginning of the telephone conversation if recording will be necessary);

website security questions and answers; and

your website user name combined with your passwords.

Similar information for other individuals included in your application form.
To provide you with the service (contract)
To check your identityContact details such as your name, address, email address and telephone number;

your date of birth, nationality and national client identifier information, national insurance number, passport details, tax identification number and driving licence details;

your bank account details or other payment or financial information;

information on your current shareholdings or other products including details of any other persons included in such holdings or product;

your shareholder reference number (IVC); and

a record of any correspondence you have with us.

Similar information for other individuals included in your application form.
To provide you with the service (contract)
To prevent and detect financial crime such as money laundering, sanctions breaches, tax evasion and fraudContact details such as your name, address, email address and telephone number;

your date of birth, nationality and national client identifier information, national insurance number, passport details, tax identification number and driving licence details;

your bank account details or other payment or financial information;

information on your current shareholdings or other products including details of any other persons included in such holdings or product;

your shareholder reference number (IVC);

a record of any correspondence you have with us, including certain telephone calls which we may be legally required to record (but we will inform you at the beginning of the telephone conversation if recording will be necessary);

website security questions and answers; and

other information relevant to the service.

Similar information for other individuals included in your application form.
To meet obligations imposed on us by laws and regulations, tax authorities and regulators (legal obligation)
So that we can communicate with you as necessaryContact details such as your name, address, email address and telephone number;

your date of birth, nationality and national client identifier information, national insurance number, passport details, tax identification number and driving licence details;

your shareholder reference number (IVC); and

a record of any correspondence you have with us, including certain telephone calls which we may be legally required to record (but we will inform you at the beginning of the telephone conversation if recording will be necessary).

Similar information for other individuals included in your application form.
To provide you with the service (contract)
To carry out analysis about our services and how we might improve themContact details such as your name, address, email address and telephone number;

your date of birth, nationality and national client identifier information, national insurance number, passport details, tax identification number and driving licence details;

your shareholder reference number (IVC);

a record of any correspondence you have with us, including certain telephone calls which we may be legally required to record (but we will inform you at the beginning of the telephone conversation if recording will be necessary); and

other information relevant to the service.

Similar information for other individuals included in your application form.
Internal analysis and service improvement (our legitimate interest)
To resolve any complaints you may haveContact details such as your name, address, email address and telephone number;

your date of birth, nationality and national client identifier information, national insurance number, passport details, tax identification number and driving licence details;

your shareholder reference number (IVC);

a record of any correspondence you have with us, including certain telephone calls which we may be legally required to record (but we will inform you at the beginning of the telephone conversation if recording will be necessary); and

other information relevant to the service and to your complaint.

Similar information for other individuals included in your application form.
To provide you with the service (contract)
To comply with our legal or regulatory obligations.Contact details such as your name, address, email address and telephone number;

your date of birth, nationality and national client identifier information, national insurance number, passport details, tax identification number and driving licence details;

your shareholder reference number (IVC);

a record of any correspondence you have with us, including certain telephone calls which we may be legally required to record (but we will inform you at the beginning of the telephone conversation if recording will be necessary); and

other information relevant to the service.

Similar information for other individuals included in your application form
Meet obligations imposed on us by laws and regulations and by tax authorities and regulator (legal obligation)
For our own internal and external management information purposes, maintaining accounting records, analysis of financial results, internal audit requirements, receiving professional advice.Contact details such as your name, address, email address and telephone number;

your date of birth, nationality and national client identifier information, national insurance number, passport details, tax identification number and driving licence details;

your shareholder reference number (IVC);

a record of any correspondence you have with us, including certain telephone calls which we may be legally required to record (but we will inform you at the beginning of the telephone conversation if recording will be necessary); and

other information relevant to the service.

Similar information for other individuals included in your application form
Maintain appropriate records to monitor performance and evaluate business performance (our legitimate interest)

Where you have specifically consented to receive this information or where either we or a company in which you have invested has a legitimate business interest to do so, we may also contact you for feedback on the service you received from us or to tell you about Link Market Services’ products and services which we think may be of interest to you. If you at any time prefer not to receive such communications you can let us know at any time by contacting us using the details contained at the end of this document.  

7. Who do we share personal information with?

We will only disclose your personal information in accordance with applicable laws and regulations. We will disclose your information to the following third parties:

  • any member of the Link Group which means our subsidiaries, our ultimate holding company and its subsidiaries (from time to time) as necessary to perform or provide the relevant service to you or to accommodate your request;
  • the company in which you have invested, such company’s registrar and/or nominee provider and Euroclear UK & Ireland Limited (if entitled to such information), all of which may disclose such information to any person with legal or regulatory power over them such as regulatory, tax or governmental authorities, as appropriate;
  • any person with legal or regulatory power over us (such as the Financial Conduct Authority, police or the Serious Fraud Office) that may require disclosure on legal grounds, or other relevant Government departments where reasonably necessary in relation to  financial crime and sanctions regulations;
  • any replacement provider of services we offer;
  • service providers engaged by us to help us run our business and perform the relevant services requested by you. Such service providers will include, for example, cloud storage providers (engaged by us to provide electronic storage facilities for our business data and your information), brokerage and/or custodian firms (engaged by us to facilitate deals in securities you instruct us to undertake or to hold securities on your behalf), printer and mail firms (engaged by us or by the company in which you have invested, to facilitate the printing and mail-out of communications and documents relating to the relevant service provided to you), IT system suppliers, auditors, lawyers, marketing agencies, document management providers, tax advisers and providers of risk management platforms and reporting tools (engaged by us to record governance, risk and compliance in accordance with best practice risk management procedures);
  • your relatives, powers of attorney, guardians acting on your behalf or other people or organisations associated with you such as your financial advisor or your lawyer whenever you have given us permission to share your personal information with them;
  • providers of identification and verification services; and
  • other parties in commercial relationships with Link, including financial organisations and advisors where necessary to enable us to fulfil our service to you.

Some of these third parties (including Link Group subsidiaries and service providers) may be outside of the European Economic Area (EEA). We will ensure that any such subsidiary or service provider has put in place adequate safeguards to ensure that your information is held securely and in accordance with this Privacy Notice. We will also place such subsidiary or service provider under contractual obligations requiring it to meet adequate standards to protect your information. Transfers within the Link Group will be covered by an agreement entered into by members of the Link Group (an intra-group agreement) which contractually obliges each member to ensure that your Personal Data receives an adequate and consistent level of protection wherever it is transferred within the Group.

8. How do we keep your personal information secure?

We store the information you provide about yourself in a secure database and take appropriate security measures to protect such information from unauthorised access.  We take protection of your personal information and our system security very seriously.  Any personal information which is collected, recorded or used in any way will have appropriate safeguards applied in line with our data protection obligations. We implement internal and external audits and regular, independent assurance exercises across our business to ascertain the effectiveness of our security control environment and our security strategy. Your information is protected by controls designed to minimise loss or damage through accident, negligence or deliberate actions. Our employees also protect your personal and confidential information whenever they are processing it and must undertake annual training on this.

Our security controls are aligned to industry standards and good practice; providing a control environment that effectively manages risks to the confidentiality, integrity and availability of your information.

All exchanges of information between you and our website go through encrypted channels in order to prevent interception of your information. Public access to your information via this website is protected by a login using your user ID and password. You should ensure that these are kept secret and not divulged to other people.

You recognise that your use of our website is entirely at your own risk. As Link websites are grouped to the internet, which is inherently insecure, Link cannot guarantee the information you supply will not be intercepted while being transmitted over the internet.  Accordingly, Link has no responsibility or liability for the security of personal information transmitted by you via our website.

9. How long will we store your information for?

We generally hold your personal data on our systems for as long is necessary to provide the requested services to you and, where you have agreed to specific terms and conditions for a particular service, for as long as is necessary to perform our role under those terms and conditions and to comply with our regulatory obligations. The time period for which we hold your personal data in relation to a specific service or product will be set out in the terms and conditions and/or the privacy notice made available to you in relation to such specific service. Should our website use Google Analytics a record of some of your personal data (e.g. IP address) will be retained for 38 months.

For all other personal data, we will ordinarily hold your personal data on our systems for up to 7 years from the date you cease to use our services in order to allow us to comply with our regulatory obligations. In some cases where there may be a dispute or a legal action we may be required to keep personal information for longer. Where we are processor, we will hold data in accordance with the instructions of the controller (e.g. the company that you hold shares in).

If we anonymise your personal information so that it can no longer be associated with you, it will no longer be considered personal information, and we can use it without further notice to you.

10. What are your rights?

You have the following rights in relation to how we use your information. If you’d like to exercise these rights please contact us using the contact details listed at section 13 (Who can you speak to at Link about this Privacy Notice) of this Privacy Notice.

Right to lodge a complaint
You have the right to complain to the relevant supervisory authority at any time if you object to the way in which we collect and use your personal information:

In the UK: the Information Commissioner’s Office. You can contact the Information Commissioner’s Office via their website at https://ico.org.uk/concerns/ or by calling their helpline on +44 (0)303 123 1113. 

In Ireland: to the Data Protection Commissioner. You can contact the Data Protection Commissioner’s office via their website at www.dataprotection.ie or by calling them on +353 (0761) 104 800.

Right of access
To know if we are using your information and, if so, the right to access it and information about how we are using it.  There will not usually be a charge for dealing with these requests. Your personal information will usually be provided to you in writing,  unless otherwise requested. Where you have made the request by electronic means the information will be provided to you by electronic means where possible.

Right of rectification
We take reasonable steps to ensure that the personal information we hold about you is accurate and complete. However, if you do not believe this is the case you have the right to require us to rectify any errors in the information we hold about you.

Right to erasure
You have the right to require us to delete your information if our continued use is not justified. However, this will need to be balanced against other factors, depending upon the type of personal information we hold about you and why we have collected it, there may be some legal and regulatory obligations which mean we cannot comply with your request.

Right to restrict processing
In some circumstances, although you may not be entitled to require us to erase your information, but may be entitled to limit the purposes for which we can use your information.

Right of data portability
You have the right to require us to provide you with a copy of the personal information that you have supplied to us in a commonly used machine-readable format or to transfer your information directly to another controller (e.g. a third party offering services competing with ours). Once transferred, the other party will be responsible for looking after your personal information.

Right to object to direct marketing
You can ask us to stop sending you marketing messages at any time. Please see below.

Right not to be subject to automated-decision making
Link does not make decisions about you using automated decision making or profiling of your personal data.

Right to withdraw consent
For certain limited uses of your personal information if applicable, we may ask for your consent. Where we do this, you have the right to withdraw your consent to further use of your personal information.  If you withdraw your consent, we may not be able to provide certain products and services to you. If this is the case, we’ll tell you at the time you ask to withdraw your consent.

In some circumstances exercising some of these rights will mean we are unable to continue providing you with our services or maintaining a business relationship with you.

You can make any of the requests set out above using the contact details in this Privacy Notice. Please note that in some cases we may not be able to comply with your request for reasons such as our own obligations to comply with other legal or regulatory requirements. We will always respond to any request you make and if we can't comply with your request, we will tell you why.

Marketing
You are in control of how we use your information for marketing and we will only contact you if you have purchased one of our products or expressed an interest in attending one of our events. In these circumstances we may share information within the Link Group to inform you of other similar products and services that may be of interest to you, unless you tell us that you do not wish to receive this information.

If you wish to unsubscribe from any emails sent by us, you may do so at any time by following the unsubscribe instructions that appear in the email. Otherwise you can always contact us using the details set out in this Privacy Notice to update your contact preferences. In such circumstances, we will continue to send you service related (non-marketing) communications where necessary.

11. How do our websites use my Internet Protocol (IP) address and collect cookies?

Each time you use our websites, we may automatically collect certain technical information, including the type of browser you use, the Internet Protocol (IP) address used to connect your computer to the internet, and information about your visit, including the full Uniform Resource Locations (URL), clickstream to, through and from our sites, traffic data and other communication data, the resources that you access, and the information derived from the cookies we place on your mobile device and/or computer.

In order to improve the quality of our website and services, we may from time to time send your computer a "cookie". Cookies are text files that identify your computer to our server and are stored on your device. Cookies in themselves do not identify the individual user, just the computer used. Cookies enable us to improve your user experience by avoiding the need for you to enter the same information more than once. They also allow us to analyse user behaviour to improve the functionality and performance of our website.

We comply with the EU cookie regulations as introduced in the UK and Ireland on 25 May 2011 through the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011. There are two types of cookies that may be stored on your device:

  • "session cookies", which only last for the duration of your visit to our website and are automatically deleted from your device when you close your browser; and
  • "persistent cookies", which remain on your device after you have visited our website and are not deleted when you close your browser. Persistent cookies are sent back to our server every time you visit our website.

We may make use of session cookies, which are essential to maintain security throughout the site, and are not used for tracking purposes. Session cookies are used to help us remember your movements from page to page, avoiding the need for you re-enter the same information. Session cookies are held in memory and expire when you leave our website.

In addition, in order to develop our site in line with customers’ needs, Link may use an analytics and optimization service provided by WT EMEA Acquisitions Ltd (WebTrends) to track and analyse how parts of the site are used. We use this information to help improve the site. If applicable, the data collected by WebTrends will be stored exclusively for analytical purposes and does not result in any personally identifiable data being collected or stored. WebTrends will send your computer a persistent cookie in order to evaluate your use of this site. WebTrends store the information collected by the persistent cookie on servers in the United States, European Union Member States and other countries. WebTrends may also transfer this information to third parties where required to do so by law, or where such third parties process the information on WebTrends' behalf. WebTrends will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. WebTrends will not associate your IP address with any other data held by WebTrends. Link uses WebTrends to optimise this site and improve the service we provide to our visitors. This ensures that the website is fully functional and optimised to create the best possible user experience.

Our website may use Google Analytics, a web-based analytics tool that tracks and reports on the manner in which the website is used to help us to improve it. If applicable, Google Analytics does this by placing small text files called ‘cookies’ on your device. The information that the cookies collect, such as the number of visitors to the site, the pages visited and the length of time spent on the site, is aggregated and therefore anonymous. The retention period for data that is associated with cookies, user identifiers or advertising identifiers is 38 Months.

We never gather other information from your disk or computer. We will collect a copy of the data held by the cookie from inclusion in any analysis. We use full SSL protocols when collecting visitor information on secure pages; this ensures that the site’s security is not compromised. We encrypt all transmitted visitor information (even from non-secure pages), so no-one else can read the information we gather. None of the cookies used on our websites collect, record or store personally identifiable information about you.

By continuing to use this website, you are consenting to us placing session cookies on your device for the purposes detailed above.  Most users will be able to adjust their internet settings to accept all cookies, to notify them when a cookie is issued, or not to receive cookies at any time. The last of these, of course, means that certain personalised services cannot then be provided to that user. Please note that the websites to which this site may be linked may also make use of their own cookies. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

12. Following links from our websites

Our site may contain links to other sites. Such other sites may also make use of their own cookies and will have their own privacy policies. You should carefully review the privacy policies and practices of other sites, as we cannot control or be responsible for their privacy practices. We do not accept any liability for the privacy practices of such third party websites and your use of such websites is at your own risk.

13. Changes to this Privacy Notice

Please note that this policy will be reviewed and may be changed from time to time. Any changes we may make to our privacy notice in the future will be posted on this page.

14. Who can you speak to at Link about this Privacy Notice?

Questions, comments and the exercise of your rights regarding this Privacy Notice and your information are welcomed and should be addressed:

In the UK: to the Data Protection Officer by email at lmsdpo@linkgroup.co.uk or by post to the Data Protection Officer, Link Market Services, The Registry, 34 Beckenham Road, Beckenham, Kent, BR3 4TU.

In Ireland: to the Data Protection Officer by email at enquiries@linkgroup.ie or by post to the Data Protection Officer, Link Asset Services, 2 Grand Canal Square, Dublin 2, D02 A342

quoting your full name and address, the name of the company that you may have invested in and your investor code (where you have received this on a statement in relation to your product).

If you wish to make a complaint on how we have handled your personal information, you can contact our Data Protection Officer. Whilst we hope that we can resolve any complaints for you, you also have the right to complain to the relevant supervisory authority about our collection and use of your information:

in the UK: the Information Commissioner’s Office. You can contact the Information Commissioner’s Office via their website at https://ico.org.uk/concerns/ or by calling their helpline on +44 (0)303 123 1113. 

in Ireland: to the Data Protection Commissioner. You can contact the Data Protection Commissioner’s office via their website at www.dataprotection.ie or by calling them on +353 (0761) 104 800.

© 2019 Link Market Services Limited. All rights reserved.

Updated: April 2019