Privacy Policy

Our Privacy Policy:
This privacy policy sets out how www.businessptotection.uk (“the Site”) uses and protects any information that you disclose or is collected when you use this website.​We are Darwin Capital Limited a company registered in England and Wales (Company No. 05329327) with its registered office at 24 Bedford Row, London, WC1R 4TQ (“we”, “our”, “us”, “the Company”). We are a “Data Controller” for the purposes of the current Data Protection Act 1998 and we will remain so under the General Data Protection Regulation ((EU) 2016/679) (“GDPR”) and the legislation replacing the 1998 Act whilst undertaking our business services. This Privacy Policy applies to all of the products, services and websites offered by the Company or its subsidiaries or affiliated companies. Sometimes we may post product-specific privacy notices to explain our products in more detail. If you have any questions about this Privacy Policy, please feel free to contact us through our website.We are committed to ensuring that your privacy is protected. This Privacy Policy sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us. Please read the following carefully as it contains important information on our practices regarding your personal information and how we, as a data controller, will treat personal information you provide to us through the Site, including the information we collect, what we do with the information you provide to us and who we may share your information with. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.Darwin Capital Ltd may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 16th July 2020.​DATA PROTECTION PRINCIPLES We will comply with data protection law and principles, which means that your information will be:
  • Used lawfully, fairly and in a transparent way;
  • Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
  • Relevant to the purposes we have told you about and limited only to those purposes;
  • Accurate and kept up to date;
  • Kept only as long as necessary for the purposes we have told you about; and
  • Kept securely.
WHAT WE COLLECT We may collect the following types of information:
  • Personal details such as name, telephone number and address/location;
  • Your requirement, such as for an adviser/IFA; and
  • Information such as your web request, your interaction with a service, Internet Protocol address, browser type, browser language, the date and time of your request.
HOW IS INFORMATION COLLECTED? We collect your personal information through different methods including:
  • Directly from yourselves when you sign up for an account and through communications with us;
  • Cookies;
  • Log information;
  • Affiliated services on other sites;
  • Third party applications such as widgets or add-ins; and
  • Location data from Location Finders and Mapping applications.
FOR WHAT USE We will only use your personal information when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
  • Where we need to perform the contract we are about to enter into or have entered into with you;
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
  • Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal information other than in relation to sending third party direct marketing communications to you via email. You have the right to withdraw consent to such marketing at any time. FOR WHAT PURPOSE We need all the categories of information in the list above (see WHAT WE COLLECT section above) primarily to allow us to perform our contract with you and to enable us to comply with our legal obligations. In some cases, we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below:
  • To register you as a client;
  • To process enquiries and respond to requests;
  • To communicate with you;
  • To operate and improve the Site and help make your experience better;
  • To perform our service;
  • To manage our relationship with you, including notifying your about changes to our contract or services or asking you to provide us with feedback;
  • To administer and protect the business and this website;
  • To follow up the referral with a survey assessing the service you have received from the adviser/IFA you have been referred to;
  • To improve the quality of our services;
  • We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided; and
  • From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, fax or mail. We may use the information to customise the website according to your interests.
If you fail to provide personal information If you fail to provide certain information when requested either by law, or under the terms of a contract we have with you, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time. Change of purpose 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. HOW WE USE COOKIES A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps respond to you as an individual by remember previous data stored. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.We periodically use traffic log cookies to identify traffic patterns anonymously. This can be optionally blocked by opting out of Google’s Analytics programme.We embrace the EU Law regarding privacy and specifically that the use of cookies is required for the operation of some web services. The transactional nature of the Site places it in this category and as such we will request explicit permission for the use of cookies at the earliest opportunity in the process and permit the complete destruction of transactional cookies once the transaction phase is over.Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.Externally you can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent the website operating correctly and is an unsupported environment and as such we offer no guarantee of the correct operation of the web-site. WHAT WE DO WITH THE INFORMATION WE GATHER We only share personal information with other companies or individuals in the following limited circumstances:
  • Where we have your consent. We require opt-in consent for the sharing of any sensitive personal information;
  • We provide such information to our subsidiaries, affiliated companies or other trusted businesses or persons for the purpose of processing personal information on our behalf.
  • Any third parties will be bound by contractual provisions with us and only have access to personal data to perform the described purposes, and may not use it for other purposes. Further, they must process the personal data in accordance with this Privacy Policy and as permitted by the GDPR, the Data Protection Act 1998 and subsequently the Data Protection Act 2018 (subject to royal assent), the Privacy and Electronic Communications (EC Directive) Regulations 2003 and the E-Privacy Regulations when it comes into effect.
  • Making an introduction or referral to an adviser/IFA that you have requested
  • We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce applicable Terms of Service, including investigation of potential violations thereof, (c) detect, prevent or otherwise address fraud, security or technical issues, or (d) protect against harm to the rights, property or safety of the Company its users or the public, as required or permitted by law.
  • If the Company becomes involved in a merger, acquisition or any form of sale of some or all of its assets, we will ensure the confidentiality of any personal information involved in such transactions and provide notice before personal information is transferred and becomes subject to a different privacy policy.
SECURITY We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.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.Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question. 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.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.Details of retention periods for different aspects of your personal information are available in our retention policy which you can request from us by contacting us. CONTROLLING YOUR PERSONAL INFORMATION It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your business relationship with us.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 copy of the personal information we hold about you 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. 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. You also have the right to object where we are processing your personal information for direct marketing purposes.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.Request the transfer of your personal information to another party.If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact nigel@darwincapital.co.uk or write to: The Data Controller, Darwin Capital Limited, 6 The Meadows, Portsmouth Road, Guildford GU2 4DT. Please note, there are some specific circumstances where these rights do not apply and we can refuse to deal with your requestYou will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.Right to withdraw consentIn the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact nigel@darwincapital.co.uk or write to: The Data Controller, Darwin Capital Limited, 6 The Meadows, Portsmouth Road, Guildford GU2 4DT. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. Complaints: We take any complaints we receive about the collection and use of personal information very seriously. We would encourage you to bring it to our attention if you think that our collection or use of information is unfair, misleading or inappropriate. You can make a complaint at any time by contacting us (see contact details section below).If you think our collection or use of personal information is unfair, misleading or inappropriate or if you have concerns about the security of your personal information, you also have the right to make a complaint to the Information Commissioner’s Office. You can contact the Information Commissioner’s Office at the following address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF Contact us:​You can e-mail us at nigel@darwincapital.co.uk or write to: The Data Controller, Darwin Capital Limited, 6 The Meadows, Portsmouth Road, Guildford GU2 4DT or using telephone number 07941102536.