Privacy Policy

Privacy Policy

Ascencia Investment Management is part of Frenkel Topping Group and is authorised and regulated by the Financial Conduct
Authority.

This privacy notice explains how we use any personal information we collect about you.

Ascencia Investment Management is committed to protecting the privacy of the people that we receive information about.
This means that we take steps to lawfully, fairly and transparently process any personal data that is made available to
us, in accordance with the General Data Protection Regulation (Regulation (EU) 2016/679) and any other applicable
domestic legislation (the “Data Protection Laws”). This Privacy Notice, together with our website Terms and Conditions
set out the basis on which we will process your personal data. If you have any queries about this Notice or how we use
your data, you can contact us using the contact details below.

When we refer to “personal information” or “personal data” in this Notice, we mean information which identifies you as
an individual, or is capable of doing so. In the context of this Notice, the terms “personal information” and “personal
data” may be used interchangeably. Please read this Notice carefully. By providing your personal data to us and/or
applying to use our services, you acknowledge that your personal data will be used in accordance with this Notice and
our Terms and Conditions.

When Do We Collect Information?

We may collect personal information about you when:

• you, or someone acting on your behalf, enquires about our services.
• you register with us, apply to use any of our services, become our client, or contact us in person, by telephone, by
  e-mail or by post and we go on to provide services to you.
• you voluntarily complete customer surveys, provide feedback or complete a contact form on our website.

In most instances, we will be the data controller, as defined under applicable Data Protection Laws, of any personal
data which we collect from or about you.

Information may also be collected about you when you visit our websites (for example via cookies). We record all calls
for training and quality purposes and to enable us to deal effectively with queries or complaints and in the case where
customers place transactions on regulated markets, in order to comply with our regulatory obligations.

What Information Will We Collect?

Ascencia Investment Management may collect the following information from its clients (financial intermediaries):

• Your contact details, such as your name, business address, telephone number and email address.
• Your date of birth.
• Details of the services you request from us.
• Details of your firm’s information on the FCA Register and Companies House where relevant.
• We may collect information from others within your firm for example details of directors.

In some cases, you are not obliged to provide any personal data to us, but if you have requested information or a
service from us, we will not be able to provide it without certain information, such as your contact details. Before we
can begin providing you with our services, we need to obtain certain information about you, so that we can enter into a
contract with you and carry out necessary due diligence.

You are obliged to provide this information and if you do not provide it, we will be unable to provide you with our
services.

Where an individual has made an enquiry through our website we may collect the information provided in the enquiry. This
may be:

• Your contact details such as name, email address and phone number.
• Details of your enquiry.

How We Will Use Your Information

We use information held about you in the following ways:

• to process your application to use our services.
• in the case of a third party whose personal information is provided to us, to process a potential client’s application
  to use our services.
• to comply with our obligations arising from any contracts entered into between you and us, including the Terms, and to
  provide you with the information, products and services that you request from us.
• to help protect your information and prevent unauthorised access to it.
• to deal with any queries, complaints or problems reported by you.
• for payment verification, debt tracing and debt recovery.
• to enable you to participate in our promotions.
• to provide you with information about other services we offer that are similar to those that you have already engaged us
  to provide, or enquired about. You may opt out of receiving this information when we collect your details or at any time
  by contacting us using the contact details below.
• if required to do so by law and to the extent necessary for the proper operation of our systems, to protect us/our
  customers, or for the enforcement of our Terms.
• to notify you of changes to our services; and
• to help improve the services we provide to you.

The primary legal basis that we intend to use for the processing of your data is for the performance of our contract
with you. The information that we collect about you is essential for us to be able to carry out the services that you
require from us effectively. Without collecting your personal data we’d also be unable to fulfil our legal and
regulatory obligations.

Data protection laws define the following as special categories of data:

• data revealing your racial or ethnic origins, your political opinions, religious or philosophical beliefs, or any trade
  union membership you may hold.
• genetic data or biometric data about you.
• data concerning your health, your sex life or your sexual orientation.

It is unlikely we will collect special category data from you but where special category data is required, we’ll obtain
your explicit consent in order to collect and process this information.

How We Protect Your Information

We take appropriate security measures (including physical, electronic and procedural measures) to help protect the
confidentiality, integrity and availability of your personal information from unauthorised access and disclosure. For
example, only authorised employees are permitted to access personal information, and they may do so only for permitted
business functions. In addition, we use firewalls to help prevent Disclosure of Your Information

Who we may share your information with

We may disclose your information:

• Where you have given consent, to businesses that are legally part of the same group of companies as Ascencia Investment
  Management, or that become part of that group.
• Where you have consented to receiving information regarding other products and services from Frenkel Topping Group plc
  and other firms within the group your data will be shared with other firms in the group for this purpose and contact
  details stored on a group client management system. Intermediaries can withdraw consent at any time and their data will
  be removed.
• To our IT providers, services providers and agents in order to provide and maintain the provision of the services.
• To our appointed auditors, accountants, lawyers and other professional advisers, to the extent that they require access
  to the information in order to advise us.
• To fraud prevention agencies. We will supply details of such agencies on request.
• If required to do so by the Financial Conduct Authority or any relevant regulatory authority where they are entitled to
  require disclosure.
• If required to do so to meet applicable law, the order of a Court or market rules and codes of practice applicable to
  the circumstances at the time.
• To investigate or prevent fraud or activities believed to be illegal or otherwise in breach of applicable law.

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.

We will not lend or sell your information to third parties persons from gaining access to your personal information.

Transferring Information Overseas

The organisations to whom we may pass your details also have their own obligations to deal with your personal
information appropriately. Sometimes a product or service may be administered from a country outside Europe. If this is
the case, the firm must put a contract in place to ensure that your information is adequately protected.

Your Rights

You have the following rights (unless exemptions apply), which can be exercised by contacting us using the details
provided below. The right:

• To ask us not to process your personal data for marketing purposes.
• To access personal information held about you and to obtain a copy of it.
• To obtain the rectification or completion of personal data which are inaccurate or incomplete.
• To restrict or object to the processing of your personal data and to request its erasure under certain circumstances.
• In certain circumstances, to receive your personal data, which you have provided to us, in a structured, commonly-used
  and machine readable format and the right to transmit that data to another data controller without hindrance, or to have
  that personal data transmitted to another data controller, where technically feasible.
• To be informed about any use of your personal data to make automated decisions about you, and to obtain meaningful
  information about the logic involved, as well as the significance and the envisaged consequences of this processing; and
• To lodge a complaint about the way in which your personal data is being used to the Information Commissioner’s Office
  (https://ico.org.uk/global/contact-us)

When you contact us to exercise any of the rights above, we may ask you to provide some additional information in order
to verify your identity, such as your name, your address and proof of identity.

Where we rely on your consent to use your personal data, you have the right to withdraw that consent at any time.

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.

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:

0303 123 1113 (local rate)

Changes to our privacy policy

We keep our privacy policy under regular review, and we will inform you of any changes when they occur. we would advise
you to check the website regularly to ensure that you are familiar with the most up-to-date version.

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
denise.moore@frenkeltopping.co.uk or write to us at Frenkel House, 15, Carolina Way, Manchester. M50 2ZY.