Privacy Policy

Introduction

Fleming Advisers Limited recognises the importance of protecting your personal data. This Privacy Notice explains how we collect, store and use your personal data when you visit our website or subscribe to our materials and publications or purchase our products or services or apply for a job with Fleming Advisers Limited in compliance with applicable data protection law.

When used in this Notice, unless otherwise stated, the terms “controller”, "personal data", "process", "processes", and "processing" have the meanings given to them in the UK General Data Protection Regulation.

 1. Who we are

2. What personal data we collect and how we collect it

3. How we use cookies

4. How we use personal data

5. How we retain your personal data

6. Your personal data protection rights

7. How to contact us

 1.      Who we are

Fleming Advisers Limited (Fleming Advisers) is a private limited company (England and Wales registration number 15091239). Fleming Advisers’ registered address is Lynton House, 7-12 Tavistock Square, London WC1H 9BQ. Unless we inform you otherwise, Fleming Advisers Limited will be the data controller and responsible for your personal data.

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below:

Full name of legal entity: Fleming Advisers
Email address: contact@flemingadvisers.com

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

 2.      What personal data we collect and how we collect it

(a)    Data that you give to us. This is information that you provide to use when you sign up to receive news and updates, fill in contact forms, correspond with us by telephone, post, email or otherwise, sign up to events, give us a business card or provide us with your CV when you apply for a job with us.
(b)    Data that the site collects about you. Fleming Advisers’ website collect some information automatically about you and your visit including internet or other network activity such as internet protocol (IP) address, browser type and version and the pages on the site that you visit.
(c)    Data collected from our other systems. If you correspond with us by email or other means of communication, our information technology systems may record details of those conversations, sometimes including their content.
(d)    Data collected from other sources. Fleming Advisers may collect data from other sources, for instance if your colleagues or other business contacts provide us with your contact details or with information about the nature of your role in the business relationship.

Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are:

a)     Where we have a contractual obligation
b)     Where we have a legal obligation
c)      Where we have a vital interest
d)     Where we have a legitimate interest

Generally we do not rely on consent as a legal basis for processing your personal data but where we do, you have the right to withdraw consent at any time by contacting us (see below). We will obtain your consent, however, before sending third party direct marketing communications to you, or where your consent is otherwise required under applicable law.

 3.      How we use cookies

This website uses cookies. By using this website, you consent to their use. When you access our website, we place several cookies in your web browser with your permission which we use to control the frequency of the requests and to distinguish users.

Necessary cookies enable core functionality such as security, network management, and accessibility. You may disable these by changing your browser settings, but this may affect how the website functions.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

 4.      How we use personal data

We may use your personal data to provide clients and customers with services such as client services, training, registering you as a client, managing our relationship with you, administering and protecting our business, using data analytics to improve our website, administering job applications, conducting research projects and complying with our legal obligations. We do not sell personal information to anyone and we share it only with third parties who support the delivery of services provided by Fleming Advisers.

To the extent that you provide us with personal data of third parties, you agree and acknowledge that you have informed them of, and they have agreed to, our use, collection and disclosure of their personal data including the purposes of such use, collection and disclosure of personal data as set out in this notice.

 5.      How we retain your personal data

Your information is securely stored. Subject to applicable law, we retain your information for (as the case may be):

a)     As long as it is required for our legitimate purpose;
b)     As long as it is required to perform our contractual obligations;
c)      As long as we have your consent; or
d)     Such period as is required or required by law or regulatory obligations which apply to us.

 We keep marketing data for three years and we keep CVs for one year.

 We will delete or anonymise your personal data when it is no longer required.

 6.      Your personal data protection rights

Under data protection law, you have rights in relation to your personal data including:

Your right of access - You have the right to ask us for copies of your personal information.

Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.

Your right to object to processing - You have the right to object to the processing of your personal information in certain circumstances.

Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact us at contact@flemingadvisers.com if you wish to make a request.

You should be aware that when you are on the site, you could be directed to other websites that are beyond our control. There are links to other websites from the site that may take you outside our service. We cannot guarantee that the privacy policies of these websites meet our standards. You should read the privacy notice of any new website you go to.

 7.      How to contact us
If you have questions about our privacy policy or you do not want Fleming Advisers to send you e-mail or postal mail, please contact us by e-mail at contact@flemingadvisers.com

You can also complain to the ICO if you are unhappy with how we have used your data. The ICO’s address is:

 Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk

Any changes to this privacy policy will be posted on our website. This policy was last reviewed/updated: 6 September 2023.