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CAMELLIA PLC PRIVACY POLICY

ATFIN GmbH (the “Company”) is owned by Camellia plc and is part of the Camellia Group (the “Group”, "we" and "us"). Camellia is committed to protecting the privacy of those with whom we interact and we recognise the need to respect and protect information that is collected or disclosed to us (called "personal information", explained below).

This Privacy Notice is intended to tell you how we use your personal information, and we've tried to explain what we do in enough detail to give you the information you need at a glance, with the option of following a link if you want to find out more. If you still can't find the information you need, you can email us at dpo@camellia.co.uk .

The Privacy Notice applies to devices, products, websites or applications that refer to or link to the Privacy Notice (collectively, our “Services”) and will apply whether you access our Services using a computer, mobile phone, tablet, TV, or other device.

Who are we?

Camellia is made up of different legal entities, details of which can be found here www.camellia.plc.uk. This privacy notice is issued on behalf of the Group so when we mention "the Group ", "we", "us" or "our" in this privacy notice we are referring to the relevant company in the Group responsible for processing your personal information. The Company is the controller and responsible for this website.

We have appointed a data protection officer ("DPO") who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO at this email address: dpo@camellia.co.uk

What is Personal Information and what Personal Information does the Group collect about you?

For the purposes of this Privacy Notice "Personal Information" consists of any information that relates to you and/or information from which you can be identified, directly or indirectly. For example, information which identifies you may consist of your name, address, telephone number, photographs, location data, an online identifier (e.g. cookies identifiers and your IP address) or to one or more factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity. When we combine other information (i.e. information that does not, on its own, identify you) with Personal Information, we treat the combined information as Personal Information.

We may collect use, store and transfer different kinds of Personal Information about you which we have grouped together as follows:

  • Identity Data includes first name, last name and title.
  • Contact Data includes address, email address and telephone number.
  • Technical Data includes internet protocol (IP) address (IP addresses are a string of numbers assigned to a computer by an internet service provider).
  • User Behaviour / Engagement Data includes the date and time of registration, usage session dates and duration, page views, features and functions used, preferences and settings selected, and responses to surveys.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

2. How is your Personal Information collected?


Camellia collects information through its websites, email notification, and other Group products, applications, platforms, services and events (our "Products"), We use different methods to collect data from and about you including:

I. Personal Information you provide directly. You may give us your Identity, Contact and Marketing and Communications Data by filling in forms or by corresponding with us by email, phone or otherwise. This includes Personal Information you provide when you:

  • Register for our Products,
  • Set-up portfolios, preferences, and notifications/alerts connected to our Products;
  • Log into our Products and services through social media platforms;
  • Contact our customer support by email, phone or other means;
  • Participate in surveys or questionnaires;
  • Complete online order forms;
  • Use our Products;
  • Otherwise interact with us. 

II. Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data and User Behaviour/Engagement Date about your equipment, browsing actions and patterns. We collect this Personal Information by using cookies and other similar technologies. Please see section 9 below and our cookie policy for further details.

III. Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

Technical Data by using tracking and analytics tools, such as pixel tags, action tags, web beacons and JavaScript amongst others to collect and analyse information on behaviour and engagement with our Products.
Identity and Contact Date from publicly available sources such as Companies House.

4. To whom do we disclose your information?


We will only use your Personal Information for our internal business purposes, some of which are mentioned above. We do not sell any of your Personal Information to third parties. However, we may disclose your information to the following entities:

I. Camellia Affiliates

We may need to transfer your Personal Information to other Camellia Affiliates to provide the Services you require or any other services/assistance you request. All Camellia Affiliates are required to follow the privacy practices set forth in this Privacy Notice, or such other Privacy Notice that they may notify to you.

II. Service Providers

We use third party service providers to help us to administer certain activities and services on our behalf, such as analysing usage of our Services, email support services, tracking effectiveness of our marketing campaigns. We may share Personal Information about you with such third party service providers solely for the purpose of enabling them to perform services on our behalf and they will operate only in accordance with our instructions. Here are examples of third-party service providers we use:


Email Support Services– support services are provided to assist us in ensuring our email service functions so as to provide you with our Services. If you would like to know more about this support service, please contact us at dpo@camellia.co.uk
Analytics Service Providers – analytics providers are used to assist us in understanding the usage of our products/devices and other Services, to enable us to improve our Services. If you would like to know more about these service providers, please contact us at dpo@camellia.co.uk
 

III. Third parties when required by Law or to Protect our Services

We will disclose your Personal Information to comply with applicable law or respond to valid legal process, including from our regulators, law enforcement or other government agencies; to protect our customers (e.g. to prevent spam or attempts to defraud users of our Services); to operate and maintain the security of our Services (e.g. to prevent or stop an attack on our systems or networks); or to protect the rights or property of Camellia, including enforcing any terms or agreements governing the use of our Services.


IV. Other Parties At Your Direction

We may share Personal Information about you with third parties when you request to such sharing, including your financial adviser, broker, solicitor or accountant.

5. What do we do to keep your information secure?


We have put in place appropriate physical and technical measures to safeguard the Personal Information we collect in connection with our Services. In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Information on our instructions and they are subject to a duty of confidentiality. However, please note that although we take appropriate steps to protect your Personal Information, no website, product, device, online application or transmission of data, computer system or wireless connection is completely secure and therefore we cannot guarantee the security of your Personal Information.

6. Data Retention – How long we will store/keep your Personal Information


Camellia retains Personal Information for as long as necessary to fulfil the purposes for which your Personal Information has been collected as outlined in this Privacy Statement unless a longer retention period is required by law. When your Personal Information is no longer required for the purpose it was collected or as required by applicable law, it will be deleted and/or returned to you in accordance with applicable law.

 Accessing your Personal Information and other rights you have

Camellia will collect, store and process your Personal Information in accordance with your rights under any applicable data protection laws. Under certain circumstances, you have the following rights in relation to your Personal Information:

I. Subject Access - you have the right to request details of the Personal Information which we hold about you and copies of such Personal Information.
II. Right to Withdraw Consent – where you have consented to our processing of your Personal Information, you have the right to withdraw such consent at any time.  In the event you wish to withdraw your consent to processing, please contact us at dpo@camellia.co.uk
III. Data Portability – you may, in certain circumstances, request us to port (i.e. transmit) your Personal Information directly to another organisation.
IV. Rectification – we want to ensure that the Personal Information about you that we hold is accurate and up to date. If you think that any information we have about you is incorrect or incomplete, please let us know. To the extent required by applicable laws, we will rectify or update any incorrect or inaccurate Personal Information about you.
V. Erasure ('right to be forgotten') - you have the right to have your Personal Information 'erased' in certain specified situations.
VI. Restriction of processing – you have the right in certain specified situations to require us to stop processing your Personal Information and to only store such Personal Information.
VII. Object to processing – You have the right to object to specific types of processing of your Personal Information, such as, where we are processing your Personal Information for the purposes of direct marketing.
VIII. Prevent automated decision-taking – in certain circumstances, you have the right not to be subject to decision being taken solely on the basis of automated processing.

Enforcing your rights

If you wish to enforce any of your rights under applicable data protection laws, then please contact us at dpo@camellia.co.uk  We will respond to your request without undue delay and by no later than one month from receipt of any such request, unless a longer period is permitted by applicable data protection laws, and we may charge a reasonable fee for dealing with your request which we will notify to you. Please note that we will only charge a fee where we are permitted to do so by applicable data protection laws.

Complaints

It is important that you ensure you have read this Privacy Notice. If you do not think that we have processed your data in accordance with this notice, you should let us know as soon as possible. Alternatively, you may want to liaise with the ICO for further information, which is available at www.ico.org.uk

7. Third-Party Links and Products on Our Services


Our websites, applications and products may contain links to other third party websites that are not operated by Camellia, and our websites may contain applications that you can download from third parties. These linked sites and applications are not under Camellia’s control and as such, we are not responsible for the privacy practices or the content of any linked websites and online applications. If you choose to use any third party websites or applications, any Personal Information collected by the third party’s website or application will be controlled by the Privacy Notice of that third party. We strongly recommend that you take the time to review the privacy policies of any third parties to which you provide Personal Information.

8. Cookies


What are cookies?

Camellia, as well as certain other third parties that provide content, advertising, or other functionality on our Services, may use cookies and other technologies, including web beacons, action tags, pixel tags, in certain areas of our Services. Cookies are small text files that can be read by a web server in the domain that put the cookie on your hard drive. Cookies are assigned to and stored in a user's internet browser on a temporary (for the duration of the online session only) or persistent basis (cookie stays on the computer after the internet browser or device has been closed). Cookies collect and store information about a user’s preferences, product usage, content viewed, and registration information which allows for Camellia to provide users an enhanced and customized experience when engaging with our Products. We may use cookies to store your preferences and settings, help you with signing in, provide targeted ads, and analyse site operations.

Further information on cookies

For further information on what cookies are, how Camellia and other third parties use them, and for details of how cookies can be disabled, please see our Cookie Policy.

9. Your Choices (e.g. marketing related emails or otherwise)


When you purchase our Products, create an account or profile for one of our Products or subscribe to our email notification service, we and other Camellia Affiliates may use your Personal Information (such as your contact details (e.g. name, address, email address, telephone number)) to send you, marketing-related correspondence by email, telephone, post and/or text message (SMS) related to our Products, in accordance with your email and contact preferences in your Account Preferences and Personal Information sections of your Camellia website My Account or as you otherwise agree to. When we process your Personal Information for marketing purposes, we do so on the basis that it is in our legitimate interests to do so, or in the case of our email notification service, that it is necessary to perform our contract with you.

We do not share Personal Information with third parties for the third parties’ marketing purposes.

We may also use your Personal Information to personalise and to target more effectively our marketing communications to ensure, to the extent possible, that any marketing-related correspondence is relevant to you.

To opt out of receiving marketing-related correspondence from Camellia, please update your Account Preferences and Personal Information in your Camellia website My Account or click "Unsubscribe" from any marketing or promotional email or text message (SMS) you receive from us.

10. Changes to this Privacy Notice


It also is important that you check back often for updates to the Privacy Notice, as we may change this Privacy Notice from time to time. The “Date last updated” legend at the bottom of this page states when the notice was last updated and any changes will become effective upon our posting of the revised Privacy Notice.

We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent. We will provide this notice by email or by posting notice of the changes on our website or through any relevant Services.

11. Contact Us / Further Information
If you have any questions regarding the collection, processing, or use of your Personal Information or if you wish to correct, block, rectify, object, access, revoke your consent to any applicable aspect of this Privacy Notice or delete any of your Personal Information, please contact us at dpo@camellia.co.uk

Issue Number: Issue 1
Date last updated: May 2018
Author: Head of HR (UK)
Responsibility: Data Protection Officer
Review Data: May 2020

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