We are committed to protecting and respecting your privacy. We gather/use and keep information in accordance with the Data Protection legislation.
1. Personal Data Protection Arrangements
This notice sets out the arrangement made by WAY Fund Managers (we/us) to protect the personal data received while carrying out its duties as a Data Controller and Processor of Personal Data, registered as such with the Information Commissioners Office https://ico.org.uk/about-the-ico/what-we-do/register-of-data-controllers/
What is Personal Data?
Personal Data is defined by legislation as any information relating to an identified or identifiable living natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
A Senior Manager has been appointed to oversee the application of these arrangements and is responsible for ensuring that this notice is published and available to all individuals prior to the collection and processing of their personal data. All employees are responsible for ensuring the individual’s rights are respected at all time. Agents providing services must draw the individual’s attention to how their personal data will be collected and processed.
3. Fair Processing Notice
We will collect your personal data on the basis that both parties are entering a contract for the supply of services. In order to perform that contract and to arrange the service you require, we will use your personal data for the purposes detailed below. We may also use your personal data for any contractual responsibilities that we may owe to our regulator, the Financial Conduct Authority, or for wider compliance with any legal or regulatory obligation to which we might be subject. In such circumstances, we would be processing your personal data in order to meet a legal, compliance or other regulatory obligation to which we are subject.
The personal data we collect from you will be used for the following purposes:
The management and administration of your instructions in connection with your investment.
The registration of your share/unit holding.
Communications to you in regards to your share/unit holdings.
Any payments to be processed in connection with your share/unit holdings.
To verify your identity for anti-money laundering purposes
By submitting an application to invest in one of the Funds we manage you consent to entering into this contract and giving us permission to perform those actions.
At any time you may request that we provide you with a copy of the personal data we are processing. You may ask for correction of that data and withdraw your consent to our continued processing by requesting that using the contact details at the end of this document.
Should you feel that the information we hold on you is incorrect or you wish to withdraw your consent to processing you may do so at any time by contacting the Data Protection Office, using the contact details at the end of this notice.
Special Categories of Personal Data
Certain data is classified as “special categories”, full details of these categories may be found on the Information Commissioners Office website here: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/lawful-basis-for-processing/special-category-data/
Consent is required for WAY Fund Managers to process this type of personal data, but it must be explicitly given. We do not collect this information in connection with the services we will be contracting with you. Should at any time we need to ask you for sensitive personal data we will always tell you why and how the information will be used.
4. Why does WAY Fund Managers need to collect and store personal data?
In order for us to manage and administer your investment we need to collect personal data to enable us to register your share/unit holdings, administer those holdings, following your instructions, provide you with periodic statements and any information which may affect your holdings. We will also process distributions, purchases and redemptions of your units, following receipt of your instructions. We are also obliged to confirm your identity for the purpose of anti money laundering. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose and does not constitute an invasion of your privacy.
In the course of dealing with you, we will pass your personal data on to our service providers, which would include the Fund Transfer Agent and Registrar, who are contracted to WAY Fund Managers and we oversee their handling of your data. We will also share this data with an electronic identity checking service, which we use to complete the requirements of the anti-money laundering obligations and to verify changes of name and address for your protection. We may also use a mailing service to carry out bulk mailing of statements and unit/share holder letters. You will be advised on any change to data processor. Our contractors are obliged to keep your details securely and to use it only to carry out their contracted obligations with WAY Fund Managers. This sharing of your personal data does not entitle such third parties to send you marketing or promotional messages. Once your service needs has been satisfied, they will dispose of the details in line with both their own and WAY Fund Managers’ security procedures.
5. How WAY Fund Managers uses your information
WAY Fund Managers or their contracted partners will collect, store and use the information you provide in a manner that is compatible with the EU’s General Data Protection Regulation (GDPR) and the UK Data Protection Act. We will endeavour to keep your information accurate and up to date and not keep it for longer than is necessary. In some instances the law sets the length of time information has to be kept, but in most cases WAY Fund Managers will use its discretion to ensure that we do not keep records outside of our normal business requirements.
Our aim is not to be intrusive and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.
6. How to contact the WAY Fund Managers Data Protection Office.
Please contact the below should you have any questions in connection with your rights as a Data Subject and how WAY Fund Managers manages your personal data:
Data Protection Office
WAY Fund Managers Limited
3 Cedar Park
Wimborne, Dorset. BH21 7SB
Tel: 01202 855856
7. Supervisory Authority.
The UK Supervisory authority for WAY Fund Managers is the Information Commissioners Office. Should you wish, you may contact them should you wish to make a complaint in connection with the way we have handled your data. Their contact details can be found here: https://ico.org.uk/for-the-public/
We are committed to protecting and respecting your privacy. We gather/use and keep information in accordance with the Data Protection Act 1998 and other relevant legislation.
We may collect information about your computer, including where available your IP address, operating system and browser type, for administration and to report aggregate information to our business partners. This is statistical information about our users’ browsing actions and patterns and does not identify any individual. For example, how long your visit lasted and the type of browser used.
Cookies collect anonymous information about how visitors use our website including the number of site visitors, the source of visitors to our website and the web pages they visit.
The table below explains the cookies our website uses in order to deliver its services efficiently and to enhance your experience. We do not use behavioural targeting cookies.
The following table explains the cookies we use and why:
|These cookies are used to track visitor interactions. We collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the time of day and number of visitors to the site, as well as what site referred the visitor to our web pages and the pages they visited during their time with us.||Google Data Privacy|
|Session Id||wfm_preference||Issued by our servers, session cookies are essential to allow you to proceed through many pages of a site quickly and easily without having to authenticate or reprocess each new page, form or area you visit.|
|These are the WP session and user ID cookies. The number on the end is your individual user ID from the users database table and is stored on your browser for 1 year. The test cookie expires at the end of session.||WordPress Privacy|
Session cookies allow us to track your actions during a single browser session, for example to remember the items returned from a search. They do not remain on your device beyond your session.
Persistent cookies remain on your device between sessions and allow us to authenticate you and to remember your preferences. We also use them to balance the load on our servers and thus to enhance your experience on our website.
Session and persistent cookies can be either first or third-party cookies – a first-party cookie is set by the website being visited. A third-party cookie is issued by a different website to that being visited.
Our site uses a mixture of first-party, session and persistent cookies to deliver its services efficiently and to enhance your experience. The only third-party cookies used by us are those provided by Google Analytics to gather anonymised information for the benefit of all web users. We do not use behavioural targeting cookies. All our cookies fall within the ICC classifications Strictly Necessary, Functionality and Performance and none within the classification Behavioural Targeting.
If at any time you wish to disable our cookies you may do so through the settings on your browser, but if you do so your experience of using our site may be affected.
If at any time you wish to disable our cookies you may do so through the settings on your browser, but if you do so you may not be able to use certain important features of the website and/or that some sections of our website may not work as well as they otherwise would.
Our site may, from time to time, contain links to and from the websites of our partner networks and affiliates. If you follow a link to any of these website, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you send any personal data to these websites.
To find out more about cookies, the following websites contain some useful information: