Privacy
Policy

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At Attivo Investments, we are committed to protecting the privacy and security of personal data. This privacy notice explains how we collect, use, and safeguard personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and Data Protection Act 2018.
 
Who We Are
Attivo Investments is a discretionary investment manager contracting exclusively with professional clients. We are registered with the Information Commissioner’s Office (ICO) under registration number ZB834631  
 
What Data Do We Collect?
We may collect and process the following types of personal data:
•Contact details (name, job title, email address, phone number).
•Business information (company name, role, and associated firm details).
•Financial and contractual information necessary to deliver our services.
 
How We Use Your Data
We use personal data to:
1.Provide and manage our investment services.
2.Fulfill contractual and regulatory obligations.
3.Communicate effectively with you.
4.Manage business relationships.
 
We do not process personal data for marketing purposes or share it with third parties for unrelated purposes.
 
We may also collect information when you voluntarily complete client surveys or provide feedback to us.
 
Information relating to usage of our website is collected using cookies. These are text files placed on your computer to collect standard internet log information and visitor behaviour information. We will use your information collected from the website to personalise your repeat visits to the site.
 
Why do we need to collect and use your personal data?
We must have a lawful basis to process your personal data. Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are:
We have a contractual obligation
This is the primary legal basis that we intend to use for processing your data. The personal information that we collect about you is essential for us to be able to effectively carry out the services that we have agreed to deliver to you.
We have a legal obligation
Sometimes, collecting personal data is needed to meet our legal and regulatory obligations. For example, UK anti money laundering legislation may require us to collect personal information to verify your identity.
We have a legitimate interest
We rely on legitimate interest to retain relevant data for the purposes of assessing the appropriateness of our services, defending future complaints, and meeting our Professional Indemnity Insurer’s expectations.
 
How will we use the information about you?
We collect information about you in order to provide you with the services for which you engage us.
Who might we share your information with?
If you agree, we may email you about other products or services that we think may be of interest to you.
If you agree, we will pass on your personal information to our group of companies so that they may offer you their products and services.
We won’t share your information for marketing purposes with companies outside our group of companies / other companies.
In order to deliver our services to you effectively we may send your details to third parties such as those that we engage for professional compliance, accountancy, or legal services as well as product and platform providers that we use to arrange financial products for you.
 
Where third parties are involved in processing your data, we will have a contract in place with them to ensure that the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your data and that they’ll only act in accordance with our written instructions.
 
Where it’s necessary for your personal data to be forwarded to a third party we’ll use appropriate security measures to protect your personal data in transit. This will include password protection and other methods. 
 
To fulfil our obligations in respect of prevention of money-laundering and other financial crime, we may send your details to third party agencies for identity verification purposes.
How long do we keep hold of your information?
 
During the course of our relationship with you, we will retain personal data which is necessary to provide services to you. We’ll take all reasonable steps to keep your personal data up to date throughout our relationship.
 
We are also subject to regulatory requirements to retain your data for specified minimum periods. These are, generally:
•            Five years for investment business
These are minimum periods, during which we have a legal obligation to retain your records.
We reserve the right to retain data for longer where we believe it’s in our legitimate interests to do so. In any case, we’ll not keep your personal data for longer than 5 years after our relationship with you has ended.
 
You will need to decide your firm’s policy on data retention. We don’t recommend indefinite retention of data (other than where it is required for pension transfer business). Please note that where you intend to use legitimate interests as a lawful basis for processing personal data you need to undertake a test to determine that your legitimate interests reasonably outweigh the rights and freedoms of your clients under data protection law. You may wish to use this basis to justify retention of data for the purpose of defending future complaints. Please see our guidance for further details.
We recommend that you refer to your PI insurance policy and speak to your PI insurers or brokers in deciding your data retention policy.
 
You have the right to request deletion of your personal data. We will comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.
How can I access the information you hold about me?
You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please email or write to us using the contact details noted below.
When your personal data is processed by automated means, you have the right to ask us to move your personal data to another organisation for their use.
We have an obligation to ensure that your personal information is accurate and up to date. Please ask us to correct or remove any information that you think is incorrect.
Marketing
We would like to send you information about our products and services which may be of interest to you. If you have agreed to receive marketing information, you may opt out at a later date.
You have a right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please contact us by email or post, or by clicking here. Insert link as appropriate if displaying your privacy notice online.
Cookies
We use cookies to track visitor use of the website and to compile statistical reports on website activity.
For further information visit http://www.allaboutcookies.org/
You can set your browser not to accept cookies and the above website tells you how to remove cookies from your browser. However, in a few cases some of our website features may not function as a result.
Other websites
Our website contains links to other websites. This privacy policy only applies to this website so when you link to other websites you should read their own privacy policies.
What can you do if you are unhappy with how your personal data is processed?
You also have a right to lodge a complaint with the supervisory authority for data protection. In the UK this is:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Changes to our privacy policy
We keep our privacy policy under regular review, and we will place any updates on this web page (and / or) inform you of any changes when they occur. This privacy policy was last updated on xx / xx / xxxx.
How to contact us
Please contact us if you have any questions about our privacy policy or information we hold about you:
By email at Enquiries@attivoinvestments.co.uk
 
Or write to us at: Honeybourne Place, Jessop Avenue, Cheltenham, England, GL50 3SH