Privacy Policy

(last updated May 2018)

Surrenda-link is a trading name of SL Investment Management Ltd.

SL Investment Management Ltd is committed to protecting and respecting your privacy.

This Privacy Policy explains when and why we collect personal information about you, how we use it, the conditions under which we may disclose it to others and how we keep it secure.

Changes to this Privacy Policy

Any updates to this Policy will be published on our website so please check this periodically to ensure that you remain happy with any changes made. By engaging with us, you are agreeing to be bound by this Policy.

How to contact us

Should you have any questions regarding this Policy you can contact us using one of the following methods:

  • Email: info@slinvest.co.uk
  • Post: SL Investment Management Ltd, One City Place, Queens Road, Chester CH1 3BQ
  • Telephone: +44 (0)1244 317999.

Who are we?

SL Investment Management Ltd is a UK based Alternative Investment Fund Manager (AIFM) authorised and regulated by the Financial Conduct Authority. We specialise in providing investors with access to secondary insurance investments.

SL Investment Management Ltd is a registered company in England and Wales; registered number 02485382.

In collecting your personal data we take responsibility as the Data Controller. We acknowledge and agree that any personal data of yours that we handle will be processed in accordance with all applicable data protection laws in force from time to time.

How do we collect information from you?

We collect information about you when you use one of our websites, enter information via one of our web forms, or contact us via email or telephone to enquire about our range of products or services.

What type of information is collected from you?

The personal information we collect, hold and process will typically include your name, address, email address, telephone number and if applicable, company name. We may also hold a log of our communications with you made via email or telephone.

Where we provide a service, or enter into a transaction with you, we may collect and hold financial and identification information about you – for example, using a copy of your passport and utility bill to fulfil regulatory obligations in terms of Know Your Customer (KYC) checks; or processing your bank account details to make payment for the proceeds of a financial transaction.

To help us improve the type of information and range of services provided to you, we track general visitor interaction with our websites using Google Analytics tracking code. This data is analysed by us on an aggregated basis, and any personal information stored within Google Analytics is deleted on a regular basis according to our Data Retention Policy.

How is your information used?

We may use your information to:

  • send you communications which you have requested and that may be of interest to you. These may include information about our range of products and services, or updates on the financial markets in which we are active;
  • carry out our obligations arising from any contracts entered into by you and us. For example, to perform ID or bankruptcy checks with third party providers;
  • seek your views or comments on the products and services we provide via surveys;
  • notify you of changes to our services;
  • process a job application.

We review our retention periods for personal information on a regular basis. We are legally required to hold some types of information to ensure we meet our regulatory obligations - for example, details of any financial transactions we complete with you. We will hold your personal information only for as long as is necessary for the relevant activity, or as long as is set out in any relevant contract you hold with us.

Where is your information held?

All electronic personal data that we hold on you is stored on our databases in the UK. Any paper files are held securely on site, and where necessary archived at a local secure facility that complies with data protection legislation.

Who has access to your information?

We will not share, sell or rent your information to third parties for their marketing purposes without your express consent.

We may pass your information to our third party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf. For example, utilising third party service providers to complete KYC checks; or, where you have provided consent, working with third party email service providers to engage in email marketing activities.

We are obliged to share your personal information with a third party where there is a legal requirement for us to do so. For example, working with the Financial Conduct Authority in the prevention of fraud and financial crime.

Whenever we are required to disclose your information to a third party, we will only disclose the personal information necessary for them to complete the purpose for which they are engaged. We maintain contracts with such parties, requiring them to keep your information secure and to limit the use of the data solely to the activity in which they are engaged by us.

We may transfer your personal information to a third party as part of a sale of some or all of our business and assets or as part of any business restructuring or reorganisation. However, we will take steps with the aim of ensuring that your privacy rights continue to be protected.

How long will you retain my data for?

Your data will be retained for no longer than is necessary and in accordance with our Data Retention Policy.

What is the legal basis for processing the information?

When you provide your personal data to us, you are providing us with your consent to process your personal information. We may subsequently process your personal information on the basis of our legitimate interest. For example, when transacting an endowment policy purchase according to your instructions.

Your rights

You have the right at any time to ask for a copy of the personal information that we hold about you. We do not process your data by automated means so cannot provide the data in a machine readable format.

In addition to this right of access, you also have the following rights:

  • Erasure – to request deletion of your personal information.
  • Objection to processing – to object to our processing based on the legitimate interest we may have in completing a transaction with you. You may also object to any profiling we may perform relating to your marketing preferences.
  • Restriction of processing – to restrict our permission to process your personal information. For example, to change or revoke your marketing preferences.

Should you want to make a request for a copy of the information we hold about you, or to exercise one of your rights as listed above, please contact us using the contact details outlined at the top this Privacy Policy.

Should you disagree with any elements of this Privacy Policy, you also have the right to contact the lead supervisory authority in the UK (the Information Commissioner’s Office at the time of writing).

Withdrawal of consent

If you have provided us with your consent to process your data, for the purpose of using our services, you have the right to withdraw this at any time. To withdraw your consent please contact us using the contact details outlined at the beginning of this Privacy Policy.

Security precautions in place to protect the loss, misuse or alteration of your information

When you provide us with personal information, we take steps to ensure that it is treated securely and that any sensitive information is encrypted in an appropriate manner. For example, our websites utilise SSL encryption technology, indicated by a lock icon which appears next to the domain URL in your web browser.

Therefore, personal information you enter via our encrypted web forms is considered to be secure and cannot be intercepted.

However, information transmitted routinely over the Internet (for example, emails) cannot be guaranteed to be totally secure. As a result, whilst we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us routinely via the Internet, and you do so at your own risk.

Once we receive your information, we make our best efforts to ensure its security on our systems. Where we have given (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential. We request that you not to share your password with anyone.

Profiling

We may analyse your personal information to create a profile of your interests and preferences so that we can contact you with information relevant to you. We may make use of additional information about you when it is available from external sources to help us do this effectively. We may also use your personal information to detect and reduce fraud and credit risk.

Use of 'cookies'

Like most other companies we may utilise cookies on our websites. 'Cookies' are small pieces of information sent by an organisation to your computer and stored on your hard drive to allow that website to recognise you when you visit.

Cookies collect statistical data about your browsing actions and patterns and do not identify you as an individual. For example, for our professional investor websites we use cookies to determine whether you have visited our website recently, and if not, to display a disclaimer splash screen before allowing you to visit the content on our website. This can help us to improve our website and deliver a better more efficient and personalised service.

It is possible to switch off cookies by setting your browser preferences. However, turning cookies off may result in a loss of functionality when using our websites.

Links to other websites

Our website may contain links to other websites run by other organisations. This Privacy Notice applies only to our websites‚ so we encourage you to read the privacy statements on the other websites you visit. We cannot be held responsible for the privacy policies and practices of other sites even if you access these using links from our website.

In addition, if you linked to our website from a third party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party site. We recommend that you check the policy of these third party sites.

Transferring your information outside of Europe

As part of the services offered to you, the information which you provide to us may at times reside outside the European Union (“EU”). For example, should you email us from a country located outside of the EU, or should we happen to use third party providers who have servers located in a country outside of the EU.

These countries may not have similar data protection laws to the UK. By submitting your personal data, you are agreeing to this transfer, storing or processing. Rest assured that should we transfer your information outside of the EU in this way, we will take steps to ensure that appropriate security measures are taken to protect your privacy rights in accordance with this Policy.

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