This policy describes the information that we collect from you using this website, why we collect it, and your rights under the Data Protection Act 1998 and General Data Protection Regulation.
NCM Fund Services Limited, NCM Fund Services (England) Limited and NCM Depositary Services Limited are authorised and regulated by the Financial Conduct Authority. The ultimate parent is Chaplin Finance Limited – all referred to herein as the “NCM Group”.
The companies are entered on the Financial Conduct Authority's register. NCM Fund Services Limited: company number SC166074 and FCA number 183732. NCM Depositary Services Limited: company number SC453235 and FCA number 605659. NCM Fund Services (England) Limited: company number 10351562 and FCA number 757495.
You can access the Financial Services Conduct’s register on the FCA website for more information.
Use of Your Information
Before entering into an agreement with us to obtain our services:
You will be required to provide us with certain information about you which is necessary for the purpose of entering into the agreement with you and for the purposes set out below and, in our terms, and conditions. If, for whatever reason, you fail to provide us with the information we require, we will not be able to proceed with Know Your Customer (“KYC”) checks and, consequently, will not enter into the agreement with you.
We may obtain information about you from credit reference and fraud prevention agencies to assist with our legitimate interest of assessing KYC. This search will not leave a "footprint" on your credit file.
We may collect and process the following data about you:
- Information that you provide by filling in forms on our website www.ncmfundservices.com. This includes information provided at the time of registering to use our website, subscribing to our service, posting material or requesting further services. We may also ask you for information when you report a problem with our website.
- If you contact us, we may keep a record of that correspondence.
- Information that you may provide to us in relation to the prospect of entering into business with us.
- Information that you may provide to us in relation to business operations with us including name, address, email address etc.
All personal information relating to an investor of an NCM Group client, that is given to an NCM Group entity, will be retained by that entity in accordance with the contractual terms that govern that entity’s relationship with the client and the laws and regulations (including any data protection laws and regulations), of the relevant jurisdiction.
We will not use your personal data for marketing purposes unless you have consented to this.
How we use your personal information
Personal data collected by us will be used by us when we first engage with you as a potential client, after we have entered into the agreement with you and after the agreement has ended, for the following purposes: providing and administering the services under the agreement; verifying identity; customer services; complying with legal, regulatory and compliance obligations that apply to us (for example, anti-money laundering and counter-terrorism checks) and detection and prevention of fraud and other crimes; tax administration; auditing; reporting and accounting functions; statistical analysis and market research; assigning our rights or obligations to a third party; disposing of our business or assets; funding arrangements. We shall retain your information for no longer than is necessary for the purposes set out above whereupon it shall be removed from our records.
The security of your Personal Information is important to us. We follow generally accepted standards to protect the Personal Information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about the security of your Personal Information, you can contact us at firstname.lastname@example.org.
Changes to this policy
As a business, the NCM Group does not target its offering toward, and does not knowingly collect any personal information from users under 13 years of age.
Our website uses a number of cookies to gain access to, and store data on, our visitors’ computers. For more information about cookies and what they are used for, please see www.aboutcookies.org. The following is our position in relation to current cookies in use on our website, and how we store and use them.
First Party Cookies
First-party cookies are used to monitor how our clients and visitors find and use our website. We report on this activity in aggregate, and use this information solely for the purposes of improving the monitoring and functionality of our website.
- Session ID (PHPSESSID) - We use these to keep track of movement from page to page, so that a user does not get asked for the same information that they have already given to our site.
- Consent cookie –These are used to keep track of whether or not the user has granted consent for cookies to be stored on their computer.
Third Party Cookies
Third party cookies are cookies created by another party external to the NCM group, when a user accesses a page on our website. These cookies are specific to the third-party’s domain and accordingly the data held in them can be seen and managed by the third party, and not by us. We control whether or not we use the third-party service with our website, and how it is integrated and presented on our website. We do not, however, have control over the content or the cookies themselves, the use made of them or the security of that data once held by the third party.
These third parties may collect information about a visit to our website, and they may then use this along with other data in order to serve advertising which may be more relevant to a user and their interests. However, we recognise that some visitors may see this use of data as intrusive, so for information we list the third party cookies that we use to allow users to manage their settings to their specifications.
The third party sites that we use are:
- Google Analytics
We believe there is no reason for our website visitors to be concerned about the privacy implications of any of the cookies we use, but we do understand that clients may need to be made aware of the intention and scope of data stored in the cookies, which are created or updated on their computer when they visit our website. Visitors always have the option to delete these cookies from their computer between visits to our website if desired.
If you have concerns about the privacy implications of the cookies we use, then we recommend you manage your cookie settings using the cookie management tools in your web browser.