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Privacy policy

1. Introduction

This website (johnbaronportfolios.co.uk) is owned and operated by Equi Ltd, a company registered in England and Wales with company number 09642453, referred to as "we", "our" and "us" in this Privacy Policy. For the purpose of the General Data Protection Regulation (“GDPR”), we are a data controller. Our data protection registration number is ZA155534.

We recognise the importance of protecting the privacy of information collected about visitors to our website, in particular information that is capable of identifying an individual ("personal information").

This Privacy Policy (together with our Website Terms & Conditions, which are available here) sets out the basis on which we collect and use personal information you may supply to us through your conduct on the website and through membership of the subscription service. Please read the following carefully to understand our practices regarding your personal information and how we will treat it.

If you do not agree with the use of your personal information as set out in this Privacy Policy you should not submit your personal information to us. This Privacy Policy may be reviewed periodically and we may change this Privacy Policy without notice; please check this Privacy Policy regularly to ensure you understand the practices which will apply at that time.

2. Personal Information we may collect from you

Personal information about visitors to our website or members of the subscription service is generally only collected only when knowingly and voluntarily submitted by those individuals. For example, we may need to collect such information to answer any enquiries about the website or as part of the subscription service.

As visitors to our website who make enquiries through the "Your Views" page or as members of the subscription service, we collect personal information about you in order for you to take full advantage of our services.

Our web servers gather technical information, including your Internet Protocol (IP) address, your web browser type and time zone setting, etc. to assist with the diagnosis of problems or support issues with our services. However, this information is gathered in aggregate only and we do not use this information to identify individual users of the website.

3. Cookies

We may use cookies to provide you with a better experience. These cookies allow us to increase your security by storing your session ID and a way of monitoring single user access. This aggregate, non-personal information is collated and provided to us to assist in analysing the overall usage of the website.

Please note that you can activate the setting on your Internet browser to refuse the setting of all or some cookies. However, if you use your Internet browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the website.

Please also note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

also note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

4. Uses made of your personal information and the legal bases for that processing

Personal information that visitors submit to our website is used only for the purposes of:

 
  • providing you with more information about the subscription service, where you request this (as is necessary in order to take steps prior to entering into a subscription services contract with you);
  • where you sign up to become a member of the subscription service, providing you with email updates and other subscription services, and taking receipt of subscription fees, in accordance with our Website Terms & Conditions (as is necessary for the performance of the contract between you and us, which is based on those Website Terms & Conditions); and
  • where you have provided your email address, including in order to use the subscription service for a trial period, we may email you from time to time thereafter, including after your paid or trial membership expires, to inform you of website updates and our subscription service (as is necessary for our legitimate interests, including our interests in growing subscriber numbers).

Note: if you do not wish to receive such information by email, please let us know now or at any time in the future, and your details will be removed from our mailing list(s).

Copies of correspondence sent via the website, that may contain personal information, are stored in archives for record-keeping and back-up purposes (as is necessary for our legitimate interests, including our interests in keeping records of questions answered and issues resolved via the website).

5. Disclosure of your Personal Information

We may share your personal information with selected third parties, including:

 
  • business partners, suppliers and sub-contractors who assist us with the provision of email updates, hosting the website, or any other subscription services, to website visitors and members of the subscription service (including any third parties we may engage to provide you with goods or services on our behalf);
  • analytics and search engine providers who assist us in the improvement and optimisation of our website; or
  • if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our Website Terms & Conditions or to protect our rights, property, or safety or those of any third party.

6. Data security and transfers of your personal information overseas

We strive to ensure the security, integrity and privacy of personal information submitted to our website (or otherwise obtained from you), and we review and update our security measures in light of current technologies. Unfortunately, no data transmission over the Internet can be guaranteed to be totally secure.

However, we will endeavour to take all reasonable steps to protect the personal information you may transmit to us. Once we do receive your transmission, we will also make our best efforts to ensure its security on our systems (which are located in the United Kingdom). In addition, our employees and the contractors who provide services related to our information systems are obliged to respect the confidentiality of any personal information held by us. However, we will not be held responsible for events arising from unauthorised access to your personal information by third parties.

If you agree to receive the subscription service, emails sent or received by us may be transmitted through mail servers based outside the European Economic Area (EEA), including via servers based in the United States.  In these circumstances, your personal information will only be transferred on one of the following bases:

 
  • a European Commission decision provides that the country or territory to which the transfer is made ensures an adequate level of protection; or
  • where the transfer is subject to one or more of the "appropriate safeguards" for international transfers prescribed by the GDPR (for example, standard data protection clauses adopted by the European Commission); or
  • there exists another situation where the transfer is permitted under the GDPR (for example, where we have your explicit consent).

7. Your rights in relation to personal information

Under the GDPR, you have the following rights in relation to our processing of your personal information.  Please note that these rights are not absolute, and we may be entitled to refuse requests where exceptions apply.

 
  • to obtain access to, and copies of, the personal information that we hold about you;
  • to require us to correct the personal information we hold about you if it is incorrect;
  • to require us to erase your personal information in certain circumstances;
  • to require us to restrict our data processing activities in certain circumstances;
  • to object, on grounds relating to your particular situation, to any of our particular processing activities where you feel this has a disproportionate impact on you;
  • to receive from us the personal information we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of your transmitting that personal information to another data controller; and
  • where our processing is based on your consent, you may withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal.

If you are not satisfied with how we are processing your personal information, you have the right to make a complaint to the Information Commissioner’s Office.  You can also find out more about data protection issues in the UK and protecting your privacy, by visiting the Information Commissioner's Office website, which is available here: https://ico.org.uk/.

8. Links to other websites

We may provide links or reference to websites outside of our website, as well as to third party websites. These linked websites are not under our control, and we cannot accept responsibility for their content. Before disclosing your personal information on any other website, we advise you to examine the terms and conditions of using that website and its privacy statement(s).

9. How long your personal information is kept

We will retain your personal information for as long as we are interacting with you via the website or providing the subscription service to you, and for as long as permitted or required for legal purposes after the relationship between you and us has ended.

Where we collect your email address and send you updates for a trial period, we may email you from time to time thereafter to remind you of our website and subscription service (unless you object or unsubscribe at any time) but typically we will suppress your details after a period of up to two years if we have not heard from you during that time.

Where you are a member of the subscription service, we will typically retain your personal information for a period of seven years after your membership with us has come to an end. However, some information may be kept for longer than this, for example where we need to retain it for the purposes of litigation or to retain a 'suppression list' to ensure website access is restricted to eligible members.

10. Comments and suggestions

We welcome your comments and feedback; if you have any queries about this Privacy Policy or any queries about the processing of personal information we hold about you, please contact us.

If we become aware of any ongoing concerns or problems with our website, we will take these issues seriously and work to address these concerns. If you have any further queries relating to our Privacy Policy, or you have a problem or complaint, please contact us.

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