ALLOCATOR PRIVACY POLICY

This is the privacy policy of Allocator, the trading name of HedgePo Ltd, a company registered in England with registered number 08319852, and whose registered office is at 70 Rosebery Avenue, London, England, EC1R 4RR, on behalf of itself, its affiliates and subsidiaries (Allocator).

At Allocator we respect your privacy and are committed to ensuring that your personal information is used in accordance with current data protection legislation.

This Privacy Policy explains what happens to any Personal Data that you provide to us, is provided to us, or that we collect from you whilst you visit our site.

For the purposes of Personal Data processing Allocator identifies the following Data Subject categories:

  • Investment Manager Contributor (Contributor) – a representative of a company listed on the platform who shares, and updates contact data on behalf of the company.
  • Investment Manager Individual (Individual) – an individual who is listed on the platform by a Contributor
  • Subscriber to Allocator Services, both existing and former (Subscriber)

You may belong to more than one category.

Information We Collect

In running and maintaining our platform we may collect and process the following data:

Investment Manager Contributor:

  • When you register an account to become an Allocator user (“User”), we collect information such as your name, phone number, e-mail, company details, country, and a password.
  • We also collect your IP address, browser type, operating system, mobile carrier, and your ISP, and receive the URLs of sites from which you arrive or leave the Allocator website, or sites that have embedded Allocator platform technology.
  • We collect information through cookies and other technologies that allow us to recognize you and customize your experience.
  • As a User you will also be responsible for the other personal data you include in your company profile including the name and job title of any colleagues you include.

Investment Manager individual:

  • We process your name, job title, e-mail, phone number, company details, country as well as biography. 
  • The information is provided by the Investment Manager Contributor who is keeping the company account up to date.
  • Your information is made available only to those Subscribers that your company’s User has granted permission.

Subscribers:

  • When you register an account to become an Allocator user (“User”), we collect information such as  your name, phone number, e-mail, company details, country, and a password.
  • We also collect your IP address, browser type, operating system, mobile carrier, and your ISP, and receive the URLs of sites from which you arrive or leave the Allocator website, or sites that have embedded Allocator platform technology.
  • We collect information through cookies and other technologies that allow us to recognize you and customize your experience.

Use of Your Information

We process your data relying on the “legitimate interest ground”. Allocator’s legitimate business interest, and purpose of our processing your data, is to provide data and information on the firms and funds in the investment management industry. 

Processing your data also  allows us to administer your account and customize the service we provide you and other Users as well as to send you service or promotional communications through email and notices on the Allocator web platform.

We do not sell, rent, or otherwise provide personally identifiable information to third parties without your consent except where it is necessary to carry out your instructions (to process your payment information, for example) or as described in this Privacy Policy. Please note that in order to fulfil your requests for paid services, we share your payment information with our payment processor.

When you receive newsletters or promotional emails from Allocator, we will use personalized unique links or similar technologies to determine whether the email has been opened and which links you click. This enables us to provide you with email communications or other information that are more targeted to your needs. We will rely on our legitimate interests to do this, meaning the provision of electronic direct marketing of our data, services and products, unless legislation requires us to obtain your consent, in which case we will request this from you.

How long do we retain your data?

Contact details of Investment Manager Contributors, Individuals and Subscribers are stored for varying lengths depending on the nature and purpose for which it was collected. Allocator will review your personal data periodically to ensure it is still necessary to be retained for the purpose for which it was collected.

Page View data meaning statistics as to which firm has accessed your firm profile on our web product and how often is kept for the lifetime of the product so that we can understand changes to usage patterns over time.

Billing data is kept for the lifetime of our contract with you and then ongoing for seven years to comply with tax legislation.

Backups of our products are retained for a year. However, we have processes to ensure if a restore is required Subject Rights are maintained.

Use of Cookies

Cookies provide information regarding the computer used by a visitor. We may use cookies where appropriate to gather information about your computer in order to assist us in improving our website. We may gather information about your general internet use by using the cookie. Where used, these cookies are downloaded to your computer and stored on the computer’s hard drive. Such information will not identify you personally. It is statistical data. This statistical data does not identify any personal details whatsoever. You can adjust the settings on your computer to decline any cookies if you wish. This can easily be done by activating the reject cookies setting on your computer.

Logs of access recorded by IP address are used in the process of potential system abuse and crime detection. This access is anonymized unless it is related to a sign-in by a Subscriber userID.

Logs of page views and interaction with our web product are maintained to help us to provide you with a more personalized user experience in relation to the provision of services to you.

Transfers outside the EEA

We partner with companies who provide PaaS, CRM services, web servers, data centers and other services, who have access to contact data that we hold. Appropriate data protection is provided by a Model Clauses schedule in the relevant contracts.

Subscribers are globally distributed and have access to visible contact data in our products. Where Subscribers operate outside of a territory that is deemed to have “Adequate” status by the European Commission or are not certified to US/EU Privacy Shield, appropriate data protection is provided by a Model Clauses schedule in the Terms and Conditions of service.

A definition of Adequate status and a list of relevant countries can be found here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en

Model clauses permit such transfer under Article 46 of the General Data Protection Regulation (the “GDPR”). You can find a link to the model clauses here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en

 

Disclosing Your Information

We will not disclose your personal information to any other party other than in accordance with this Privacy Policy and in the circumstances detailed below:

  • In the event that we sell any or all of our business to the buyer.
  • Where we are legally required by law to disclose your personal information.
  • To further fraud protection and reduce the risk of fraud.

Third Party Links

On occasion we include links to third parties on this website. Where we provide a link it does not mean that we endorse or approve that site’s policy towards visitor privacy. You should review their privacy policy before sending them any personal data.

What are your rights in relation to our use of your information?

You have rights under data protection law in relation to our use of your information, including to:

  1. request access to your information, which you can do by emailing dp@allocator.com stating you are submitting a Subject Access Request
  2. update or amend your information if it is inaccurate or incomplete by emailing dp@allocator.com requesting an update
  3. object to certain uses of your personal data (which includes direct marketing and processing based on legitimate interests and processing for purposes of scientific or historical research and statistics) on grounds relating to your particular situation by emailing dp@allocator.com
  4. request the deletion of your information, or restrict its use, in certain circumstances (for example you can request that we erase your information where the information is no longer necessary for the purpose for which it was collected, unless certain exceptions apply) by emailing dp@allocator.com;
  5. withdraw any consents you have provided in respect of our use of your information either by clicking unsubscribe links in emails or emailing dp@allocator.com;
  6. request the return of information you have provided to us, to use for your own purposes (often called your right to data portability) where the processing is based on your consent or for the performance of a contract, and the processing is carried out by automated means;
  7. lodge a complaint with the Information Commissioner’s Office (https://www.ico.org.uk/global/contact-us/email/) [or other relevant supervisory authority].

 

We may need to ask you for further information and identification to help us to comply with this request. More information about these rights can be found at https://ico.org.uk/for-the-public/. If you have any questions about these rights, or you would like to exercise any of them, please contact us at dp@allocator.com

We may need to ask you for further information and identification to help us to comply with this request. More information about these rights can be found at https://ico.org.uk/for-the-public/. If you have any questions about these rights, or you would like to exercise any of them, please contact us at dp@allocator.com

Contacting Us

Please do not hesitate to contact us regarding any matter relating to this Privacy Policy at dp@allocator.com

Changes to this policy

We keep this privacy policy under regular review and we will place any updates on this webpage. We will inform you of any material changes to the privacy notice. This privacy notice was last updated on 24th May 2018.