Occam Partners Privacy Policy

 

1.1 Purpose

Occam Partners Ltd takes your privacy and the protection of your data seriously and this  Privacy Policy explains how we use the personal information of our customers. This  policy may change from time to time, we shall take reasonable steps to inform you in  such a case by publication on our website.

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1.2 Regulatory Setting 

The basis for this Policy is the United Kingdom Data Protection Act 2018 (‘’DPA’’) and  United Kingdom General Data Protection Regulation (‘’UK GDPR”) together with The  Privacy and Electronic Communications Regulations (‘’PECR’’) and any guidance that  may be provided by the Information Commissioner’s ORice (‘’ICO’’). 

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1.3 Principles

As a Data Controller and custodians of your information, our privacy  management practices align to the following principles:

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Accountability: We are responsible for the protection of personal information entrusted  to us. 

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Transparency and Control: We inform customers when we collect their personal  information and we acknowledge their preferences for contact. 

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Privacy by Design: We apply privacy requirements when designing our products,  services and when implementing new technologies. 

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Security: We implement technical, organisational, and physical security measures to  ensure an appropriate level of security of the personal information we control and  process. 

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Third Parties processing information: Occam Partners requires its vendors, suppliers  and partners to commit to privacy and data protection standards and regulations in all  its jurisdictions. 

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Integrity and specific purpose: We collect personal information to provide our services  based on the contract you are entering with us. Your information will also be used to  meet our legal obligations under appropriate legislation. We collect what we need to  provide you with the best service, keeping it safe and accurate, while retaining it as  needed for its intended purpose.

 

2.2 How We Use Your Information 

We use your information mainly to interact with you; to provide you with support  services, to make it easy to navigate our website, to improve our website and our  products, and to oRer you content and services that might interest you.

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We use your information as follows, where the processing is necessary to establish or  administer our agreement with you:

 

With your request, create a single sign on for access  to your Occam Partners online account; In the performance of the contracted service  we provide to you in order to make payment transfers on your behalf; Verify your identity  and entitlement to products or services, when you contact us or access our services;  Communicate with you regarding support services and provide you with critical service  updates; Provide you with technical and customer support, and enable the provisioning  of services; Where applicable, to determine your qualifications and suitability as a  client, and make decisions to provide services to you; and Determine the entity you are  connecting from. 

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We use your information as follows, where the processing is based on our legitimate  business interests to communicate with you and improve users’ experience, improve  our products and services, protect our security, and defend our legal rights to: 

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• Call you or e-mail you with updates in this statement;

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• Research and implement product improvements and product updates;

 

• Evaluate and improve the quality of our products, services, and website; 

 

• Provide you with a customised experience when you visit our website;

 

• Secure our systems and applications; 

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• Enforce our legal rights and comply with regulatory requirements;

 

• Monitor, administer, and analyse use of the website; increase our website’s functionality and user-friendliness. 

 

• We may also use your information where processing is necessary for us to  comply with legal obligations, including responding to legal process or lawful  requests. 

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Change of Purpose 

We will only use your personal data for the purposes for which we collected it, unless  we reasonably consider that we need to use it for another reason and that reason is  compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact  us. 

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If we need to use your personal data for an unrelated purpose, we will notify you and we  will explain the legal basis which allows us to do so. In certain circumstances, where required or permitted by law, we may have to process your personal data without your  knowledge. 

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2.3 Data Retention

How long will you use my personal data for? 

We will only retain your personal data for as long as reasonably necessary to fulfil the  purposes we collected it for, including for the purposes of satisfying any legal,  regulatory, tax, accounting or reporting requirements. 

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We may retain your personal data for a longer period in the event of a complaint or if we  reasonably believe there is a prospect of litigation in respect to our relationship with  you. 

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To determine the appropriate retention period for personal data, we consider the  amount, nature and sensitivity of the personal data, the potential risk of harm from  unauthorised use or disclosure of your personal data, the purposes for which we  process your personal data and whether we can achieve those purposes through other  means, and the applicable legal, regulatory, tax, accounting or other requirements.

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OR By law, FCA guidelines, we have to keep basic information about our customers (including Contact,  Identity, Financial and Transaction Data) for five years after they cease being customers in line with regulatory purposes. They also may be retained for longer than this where legally or operationally necessary.

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3. Your Rights Under the GDPR

Occam Partners Ltd is the Controller of your personal information. 

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• You have the right to request access to your information that we hold about you.

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• You have the right to request us to rectify it if you believe any of your Personal  Data is incorrect or incomplete, we will, upon your request, take steps to check it  and correct any factual inaccuracies. 

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• You have the right to request your data to be deleted, removed or erased (the  “right to be forgotten”) subject to any legal or regulatory obligations Occam Partners may have to retain it.

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• You have the right to restrict processing. Under certain circumstances, you may  ask us to restrict the processing of your Personal Data. 

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• You have the right to data portability if we hold your Personal Data electronically,  you can ask us to transfer the data to another organisation in a safe and secure  way and in a machine-readable format. 

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• You have the right not to be subject to automated individual decision-making,  including profiling.

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3.1 Contact us 

You can exercise your rights by sending an email info@occam-partners.com. You  can write to the same address if you have questions or concerns about this Privacy Policy or our privacy and security practices. You have the right to make a  complaint at any time to the Information Commissioner’s ORice (ICO), the UK  regulator for data protection issues (www.ico.org.uk).

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