PRIVACY
Privacy Policy and your protection as a client or prospective client of Russell Leach Investments
OUR COMMITMENT TO YOU
At Russell Leach Investments your privacy is a top priority. Your privacy is at the core of the way we design and build the services and products you know and love so that you can fully trust them and focus on building meaningful connections.
We appreciate that you put your trust in us when you provide us with your information and we do not take this lightly.
We do not compromise with your privacy. We design all of our products and services with your privacy in mind. We involve experts from various fields, including legal, security, engineering, product design and others to make sure that no decision is taken without respect for your privacy.
We work hard to keep your information secure. We constantly update our security practices and invest in our security efforts to enhance the safety of your information.
PRIVACY POLICY
Welcome to the Russell Leach Investments Privacy Policy. Thank you for taking the time to read it. This Privacy Policy applies beginning October 2022.
1. Information About Us
Russell Leach Investments is part of Investment Management Centre Ltd, Kemp House, 160 City Road, London, EC1V 2NX, a company registered in England and Wales.
2. What Does This Notice Cover?
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
3. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as any information relating to an identifiable person who can be directly or indirectly identified by reference to an identifier. An identifier is any piece of information that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.
4. What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 13.
The right to access the personal data we hold about you. Part 12 will tell you how to do this.
The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 13 to find out more.
The right to restrict (i.e. prevent) the processing of your personal data.
The right to object to us using your personal data for any particular purpose or purposes.
The right to data portability. This means that you can ask us for a copy of your personal data held by us to re-use with another service or business in many cases.
Rights relating to automated decision-making and profiling: We use tools such as Cookies and similar technologies stored on your device to gather data about how you use our website. Cookies are very useful and do lots of different jobs that help to make your experience on websites as smooth as possible. For example, they let you move between web pages efficiently, remembering your preferences, and generally improve your user experience.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 13.
Further information about your rights can also be obtained from the Information Commissioner’s Office (ICO) or your local Citizens Advice Bureau. If you have any cause for concern or complaint about our use of your personal data, in the first instance please contact us directly so we can resolve any problem or query. You also have the right to lodge a complaint with the Information Commissioner’s Office.
5. What Personal Data Do You Collect?
Through our website and our dating services (if you decide to take out a membership with us), we may collect some or all of the following personal data (this may vary according to your relationship with us and what data you have chosen to share): Name, email, postal address, telephone number(s), gender, nationality, ethnicity, age, date of birth, height, alcohol and tobacco consumption, occupation, whether a home owner, marital status, location, education, qualifications, work, relationship history, what sort of relationship you may be seeking, sexual orientation, any pertinent health issues or disabilities, whether you drive or own a car, if you have had any criminal convictions, other personal information such as relating to lifestyle, income, family, pets, hobbies and interests, political and/or religious beliefs, your photographs, future goals, your partner preferences, and when and how you might like to hear from us. Some of this information you choose to provide us may be considered “special” or “sensitive”. By choosing to provide this information, you consent to our processing of that information. We may also collect data through the use of Cookies on our website, see 6 below.
6. Cookies
Our website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use. Cookies are small text files that are placed on your computer's hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely. Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
If you choose not to use cookies or you prevent their use through your browser settings, you will not be able to use all the functionality of our website.
We use cookies in the following ways to:
• track how you use our website
• record whether you have seen specific messages we display on our website
• keep you signed into our website
• record your answers to surveys and questionnaires on our site while you complete them
• record the conversation thread during a live chat if we are using this function on our website
7. How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for the following purposes:
Providing and managing your account.
Supplying our products or services.
Your personal details are required in order for us to enter into a contract with you.
Personalising and tailoring our products or services for you.
Communicating with you. This may include responding to emails or calls from you.
Supplying you with information by email, telephone or post that you have opted-in to. Your may chose to unsubscribe or opt-opt of sharing any of your personal data at any time. However, if you have signed up to a contract with us for matchmaking services we can only perform this with your continued opt-in and would not refund your fee if later, you then chose to opt-out of sharing your data with us. This does not affect your Consumer Rights.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, and/or telephone, and /or text, and/or post with information, news, and offers on our products or services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
8. How Long Will You Keep My Personal Data?
We will only use and store your data for as long as it is needed where we have a legitimate business reason to do so. How long it will be stored will depend on the type of information, what it is needed for and possibly for any statutory or legal requirements.
9. How and Where Do You Store or Transfer My Personal Data?
We only store your personal data in the UK. This means that it will be fully protected under the GDPR.
10. Data Security
The security of your personal data is essential to us, and to protect your data, we take important measures that include:
The use of Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us. Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar, (where the webpage internet address is displayed) or toolbar.
When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
Any person with any access to your data will be working for Russell Leach Investments as detailed above and must abide by the same binding corporate rules regarding data processing. The only exception to this will be when we have your express permission to share limited and defined data solely for the purposes of matchmaking with other matchmaking Companies with whom we have established partnership links. In these instances, we would require such partner Companies to be fully compliant with GDPR.
Our staff receive mandatory training on Data Security and Data Protection which is reinforced through our data security policy.
11. Do You Share My Personal Data?
We will not share any of your personal data with any third parties with the following two exceptions:
Solely for the purposes of matchmaking, with other trusted matchmaking companies with whom we have established a partnership arrangement.
We may also share your data in some limited circumstances, when legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law.
12. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”. All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 13. Please provide the following to help us meet your subject data request as quickly as possible:
The personal information you want to access
The date range of the information you want to access
Anything else you feel might help us locate this information as quickly as possible
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding. We will respond to your subject access request within not more than one month of receiving it.
Normally, we aim to provide a complete response, including a copy of your personal data within that time. However, in some cases, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
13. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
For the attention of the Data Controller
Email: info@russellleach.com
14. Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection. Any changes will be made available on our website with an updated Privacy Policy which will show the version number and when last updated.
Last updated: December 2022