This Privacy Policy describes the type of personal information Holcat-Total (‘we’) may collect, the purposes for which we may use the information, the circumstances in which we may share the information, and the steps we take to safeguard the information to protect your privacy.
You are deemed to accept and consent to the practices described in this Privacy Policy by:
- Visiting our website;
- Consenting to receive specific information or communications including marketing information from us; or,
- Where you are on a third-party mailing list for events held by or on behalf of Holcat-Total.
This Privacy Policy and the use of your personal data also extends to shareholders and former shareholders where we obtain your personal data from our Registrars or a nominee shareholder who may hold shares on your behalf.
Holcat-Total is committed to maintaining the personal information it holds about you in accordance with the requirements of applicable data protection and data privacy legislation.
Any personal data you do provide or that we will collect about you will be processed only for the purposes specified in this Privacy Policy. The information you provide will be recorded, processed and retained in electronic and/or paper form. We will not request any sensitive data however if you choose to supply us with any sensitive data, which includes such things as details about your state of health, in giving such information you are deemed to be providing us with explicit consent to process the information for the purposes specified in this policy.
1. The personal information we collect
If you visit our website, in general you may do so without revealing any information about yourself. However, our servers, cookies and other tracking technologies collect the domain names and other information relating to users of this website, and we aggregate it to measure the use of and to improve the content of our website.
We will retain and use all personal data (for example name, email, address, date of birth and financial details) that you may provide to us including by telephone, email, in person or via this website (for example, when you request a factsheet, newsletter or a copy of our annual report). We may combine the information that you give us with other information we collect about you, including your name, contact details, and, if you are a shareholder, details of the shares you hold and the votes you cast. We collect this personal information when you provide details to us directly or through your agent, stockbroker or share plan administrator, including on shareholder application forms or stock transfer forms.
Your personal information will be held and processed by us as a data controller in accordance with the requirements of the General Data Protection Regulation and any other applicable legislation.
We will collect only such information as is necessary for its use (see the ‘How we use the personal information’ section below). In all circumstances, the information will be adequate, relevant and not excessive and will be processed in line with your rights.
We will not disclose your information except in the circumstances set out under the ‘Who we may disclose your information to’ section below.
We (or our agents) will collect personal information about you including: your name; residential, correspondence and email address; tax reference number; date, town and country of birth; and bank account details and any other information which we are obliged by law to collect and report.
We may also collect details of how you use our website and the attachments you may open with newsletters that are sent to you electronically.
We will collect personal information about you when you or someone acting on your behalf apply to use our services and then during the course of our relationship with you. We may collect this information in various ways including, from:
- Applications or forms that you or someone acting on your behalf may complete or agreements that you may enter into with us;
- Emails, letters and during telephone calls, when you register for services, in customer surveys and when you participate in competitions and promotions;
- Information that Holcat-Total may receive from other organisations such as fraud prevention agencies or organisers of events;
- The use of cookies on our website; and
- Newsletters or other communications that we may send you electronically.
2. How we use the personal information
Depending on the personal information we receive, we may use it in the following ways:
- Checking your identity: We may use your personal data to check and verify your identity. If you provide false or inaccurate information that results in our suspecting fraud, we will notify the relevant authorities.
- Responding to your requests and complying with your instructions: We may use your personal data to respond to your requests such as where you subscribe for our monthly factsheet, newsletters or other communications or to act on any instructions you have given us.
- Complying with regulatory and legal requirements: We may use your personal data to comply with regulatory and legal obligations, such as the prevention of fraud and money laundering, or to comply with disclosure obligations to a competent authority such as HM Revenue & Customs. This may also include contacting you by letter, telephone, email or via our website with any information that we need to send you in order to comply with our regulatory and other legal requirements.
- Complying with any reasonable request for information from a person with a legal right to it: We may use your personal data when responding to individuals such as your personal representatives following your death or your trustee in bankruptcy following your bankruptcy.
Of course, you are not required to supply any of the personal information that we may request. Please note that this may result in our not being able to properly deal with any request you have made or we may need to report the failure to disclose the information to a government agency or regulatory authority such as HM Revenue & Customs.
3. Who we may disclose your information to
Holcat-Total does not disclose your personal information to third parties, except as described in this Privacy Policy.
We may provide this information to:
- Third parties including fraud prevention and government agencies, regulatory bodies and law enforcement officials to investigate or prevent crime;
- Our service providers, agents and sub-contractors who administer or process the information on our behalf; and
- Market research companies who may assist us in improving our products and services for you.
We may also disclose personal data we hold to third parties:
(a) in the event that we sell any business or assets, in which case we may disclose personal data we hold to the prospective buyer of such business or assets; and/or
(b) if we are permitted by law to disclose your personal data to that third party or are under a legal obligation to disclose your personal data to that third party.
4. Accessing and updating your personal information
You have the right to request access to your personal information at any time to check whether it is accurate and up to date.
If you want your information removed from our records, or to restrict or object to the use we may make of your information or to obtain a copy of what we may hold, again contact us as outlined above. You can also request that we stop processing your personal data for such purposes at any time by clicking on opt-out link in any electronic marketing materials we send you. We will not process your personal data for marketing purposes or send you updates about Holcat-Total if you have informed us you do not wish to receive such materials.
5. Timely processing of the information
We will retain your personal information in accordance with applicable laws for so long as it is needed. We keep certain records, which may include personal information, for longer periods of time (including after you have sold your shareholding), if we consider that we need to do this to meet legal, regulatory, tax or accounting purposes. We will also retain information if we reasonably believe there is a prospect of complaints, challenges or litigation.
6. Keeping your information secure
We will take reasonable technical and organisational security measures to safeguard your personal information. Your information is stored securely on our computer system or that of trusted third parties and we restrict access to those who have a need to know. We provide training and education to our staff on information security. However, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security of any personal information which is transferred through the internet or email.
Internet communications are not secure unless the data being sent is encrypted. We cannot accept any responsibility for unauthorised access by a third party or the corruption of data sent to us. For security purposes we may monitor emails received or issued by us.
Messages that you send to us by email are not secure. We recommend that you do not send any confidential information to us by email. If you choose to send any confidential information to us via email, you do so at your own risk with the knowledge that a third party may intercept this information. Instructions sent by you via email and to the website are processed exclusively at your risk.
This website may contain or be linked to websites, advice or statements of third parties. We are not responsible for the content or privacy practices of any third-party websites. We make no representations as to the accuracy, completeness, timeliness or suitability of such information, and we have not and will not review or update such information and caution you that any use made of such information is at your own risk. Some of the information contained on this website may also have been prepared or provided by third parties and may not have been verified by Holcat-Total. Holcat-Total hereby excludes any liability arising out of any preparation or provision of such information for the website and makes no warranty as to the accuracy, suitability or completeness of any such information.