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To ensure the safety of our staff and our clients, we are following government guidelines surrounding Covid-19.
This means we have fewer staff available and it might take longer to answer your call. We’re very sorry for any inconvenience this may cause.
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Kensington Capital UK is a UK firm with offices in the UK only. We do have clients from all over the world and this policy is intended to comply with UK/EU requirements only. If you are outside of the EU and you have any concerns please do not hesitate to contact us for more information about how we can help you. • When we refer to Kensington Capital UK we are referring to Kensington Capital UK Ltd.
where we process your personal information for contractual performance. This includes: • Enabling us to take steps you request prior to us entering into a contract; and then; • Once we have entered into a contract, to enable us to perform the contract and to provide you with the products and services. We will process your personal information in accordance with the contract.
We may rely on legitimate interests based on our evaluation that the processing is fair, reasonable and balanced. These include: • Delivering services to our clients – To deliver the professional services our clients have engaged us to provide. • Direct marketing – To deliver timely market insights and speciality knowledge we believe is welcomed by our business clients, subscribers and individuals who have interacted with us. Where we process your personal information for our interests we will do so only where we have carefully considered both our and your interests. We will not process your personal information if our interests are overridden by your interests or fundamental rights and freedoms.
where we rely solely on your consent to process your personal information There may be circumstances where we need to, or are required to obtain and/or rely upon your consent to process your personal information. If this is the case we will give you: • the reason for needing your consent, including details as to how we will process your information • the choice as to whether to provide consent • information to enable you to withdraw your consent
Kensington Capital UK may contact you: • in relation to any service, activity or on-line content you have signed up for in order to ensure that Kensington Capital UK can deliver the services to you; • in relation to any correspondence we receive from you or any comment or complaint you make about Kensington Capital UK products or services; • in relation to any contribution you have submitted to Kensington Capital UK, e.g. on Kensington Capital UK message boards or via text or voice mail message; • to invite you to participate in surveys about Kensington Capital UK services (participation is always voluntary); and • for marketing purposes, either where we have legitimate reason to do so, or you have specifically agreed to this (see section 6 below). • Relevant webpages will give you detailed information about how Kensington Capital UK will contact you in relation to specific services, activities or on-line content.
Kensington Capital UK will only use your non-business, personal information provided by you for marketing purposes, or to promote new services, activities or on-line content where you have agreed to this.
• We will keep your information confidential except where disclosure is required or permitted by law (for example to government bodies and law enforcement agencies) or as described in section 8 below. Generally, we will only use your information within Kensington Capital UK. However, sometimes Kensington Capital UK uses third parties to process your information on our behalf. Kensington Capital UK requires these third parties to comply strictly with its instructions and Kensington Capital UK requires that they do not use your personal information for their own business purposes, unless you have explicitly consented to the use of your personal information in this way. We will never sell your information to a third party. • We will only share your information with a third party or transfer your data outside of the UK / EU if we need to. Where we do this we will comply with all of our legal obligations and we ensure that there are adequate protections in place to protect your information.
• explain why we need to share your personal information • explain the purpose for which we will be sharing it • provide you with details of the third party • obtain your explicit consent for such. • You will be able to easily withdraw your consent in the same way in which you gave it. • Where we rely on a different lawful basis, such as ‘legitimate interests’ or ‘contractual’, we will do so only to the extent permitted by such lawful basis.
If you post or send offensive, inappropriate or objectionable content anywhere on or to Kensington Capital UK websites or otherwise engage in any disruptive behaviour on any Kensington Capital UK service, Kensington Capital UK may use your personal information to stop such behaviour. Where Kensington Capital UK reasonably believes that you are or may be in breach of any applicable laws (e.g. because content you have posted may be defamatory), Kensington Capital UK may use your personal information to inform relevant third parties such as your employer, school email/internet provider or law enforcement agencies about the content and your behaviour.
Kensington Capital UK policy is not to engage nor keep information on persons under 16 years of age. If you are aged 16 or under, please get your parent/guardian to provide any personal information to Kensington Capital UK on your behalf stating clearly the purpose for sharing such information. Only where it is necessary to comply with the law will such information be recorded and kept.
We will hold your personal information on our systems for as long as is necessary for the relevant activity, or as long as is set out in any relevant contract you hold with Kensington Capital UK or Kensington Capital UK corporate retention schedule (a database that defines which documents should be kept and for how long). If your circumstances change a flag goes on the database and, while Kensington Capital UK cannot use the personal information, it stays on the system for a period of one year for administration purposes before being deleted automatically. Where you contribute material to Kensington Capital UK we will generally only keep your content for as long as is reasonably required for the purpose(s) for which it was submitted. Kensington Capital UK, as brokers of contemporary thought, also has an obligation to record snapshots of history which may include some User Generated Content i.e. content provided by the public. Therefore, some content submitted to, or shared with, Kensington Capital UK may be retained for prolonged periods of time or potentially indefinitely in Kensington Capital UK Archive, which is true of News contributions which are published. There may also be rare instances where we will share your contribution with third parties in the interests of maintaining archives. Where possible, we will endeavour to inform you upfront or let you know at a later date where we are likely to keep content indefinitely.
We place a great deal of importance on the security of all personal information. We have in place appropriate technical and security measures which are reviewed routinely. Our approach to information security is validated by our internal security audit performed by the Head of Technology.
We respect and place significant importance on your rights. The recently EU adopted General Data Protection Regulations outlines your rights, and provides further information in relation to those rights and details what we must and will do, when you wish to exercise your rights. In summary, your rights include the right to: • Basic information (such as our identity, or that of the controller if not us, the reason and basis on which we process your personal data, together with as much information to ensure fairness and transparency) and to be informed • Object: to object to processing of personal data where such is done by us in certain circumstances, for example for our legitimate interests or direct marketing • Withdraw consent: to withdraw your previously given consent • Access: to be aware of and verify the lawfulness of the processing • Rectification: to correct personal data if it is inaccurate or incomplete • Erasure: to request the removal or deletion of personal data • Restrict processing: to restrict the processing of personal data • Data portability: to obtain and reuse personal data • Be aware of any automated decision making or profiling, and to request such is restricted If you wish to object or to withdraw consent, you may contact us though one of the methods detailed below in the ‘Contact us’ section. In addition, where we have sent you a marketing email, we will have provided an ‘unsubscribe’ or ‘set your preferences’ or ‘opt-out’ link which you can use to stop any future marketing communications.