Privacy Policy

Privacy Policy Overview

This site is provided by Tiller Investments Ltd (also referred to as “Tiller”, “we”, “us”, or “our”), who is registered in England with Companies House under Company Number 10234817. Tiller is authorised and regulated by the Financial Conduct Authority. Financial Services Register Firm Reference Number (“FRN”) 793479.

We take the security of the data and information we hold very seriously and are committed to protecting and respecting your privacy. This Policy is designed to help you understand what kind of information we collect, use, share and retain in connection with our services and how we will process, use and safeguard Personal Data.

This Policy also sets out your individual rights and who you should contact if wishing to discuss the use of your Personal Data.

Please read the Policy carefully to understand our practices regarding your Personal Data.

Defining Personal Data

Personal Data is information relating to an identified or identifiable natural person. Examples include an individual’s name, age, address, date of birth and contact details.

Use of Personal Data

The main reasons we use your Personal Data are to open and service your portfolio(s), process your withdrawals, and keep you up to date with information about your portfolio(s). We may also use your Personal Data to:

  • To meet our legal obligation to check your identity, address and source of funds
  • To prevent or detect fraud or other crime
  • Administration and recordkeeping purposes
  • To improve the products, systems and services we offer to our customers
  • To customise our website for certain customers according to their interests
  • To carry out anonymous statistical analysis (we won’t be able to identify individuals when we do this)
  • To send you promotional emails about new products, special offers or other information which we think you may find interesting (unless you have opted out)

When you call us, we may monitor or record your call for training or quality assurance.

Collection of Personal Data

When you apply to register or invest with us, we ask you to give us some of your Personal Data so that we can open and service your portfolio(s). We also collect your Personal Data at other times, for example when you contact us. We are committed to keeping all the Personal Data we hold about you secure, private and confidential. This Policy explains why we need to collect your Personal Data and what we do with it. It also sets out the legal basis on which we collect and use your Personal Data and outlines the rights you have under General Data Protection Regulation (“GDPR”) (Regulation (EU) 2016/679).

We will ask for your full name (forename(s) and surname), date of birth, postal address and postcode, telephone number, email address, and nominated bank account details. We ask for your bank details so that we can make payments to you, for example when you make a withdrawal. We need this Personal Data so that we can provide you with the services that you have asked for. We also need some of this information to meet our legal obligation to check your identity, address and source of funds. If you don’t provide it, then we won’t be able to provide you with our services.

We will collect Personal Data when you register or apply to open an account through our site at www.tillerinvest.co.uk. We will also collect some of your details whenever you contact us about your portfolio(s). This can be by phone, by post, by email or secure message, or when you use our apps.

Sharing Personal Data

We use selected organisations to help us deliver the service we provide to you. We may share your Personal Data with:

  • our service providers who provide data processing services to us, for example SEI Investments (Europe) Limited (“SEI”) will provide dealing and custody services to investors who enter into a discretionary investment management agreement with us. We only share the data that’s necessary for them to provide their services. SEI is authorised and regulated by the Financial Conduct Authority. Financial Services Register Firm Reference Number (“FRN”) 191413.
  • Agencies and other organisations to check your identity, address and source of funds, and to prevent fraud and other financial crime.

We may also share your Personal Data with government bodies, law enforcement agencies, courts or other third parties to comply with our legal obligations or lawful disclosure requests.

Securing Personal Data

We are committed to ensuring the confidentiality of the Personal Data that we hold and we continue to review our security controls and related policies and procedures to ensure that your Personal Data remains secure.

When we contract with third parties, we require that they have appropriate security, privacy and confidentiality measures in place to ensure that Personal Data is kept secure.

Retention of Personal data

We keep your Personal Data where we have an ongoing legitimate or lawful need to do so. For example, we keep some records for audit purposes for up to seven years after you have closed an account with us. When we no longer have a legitimate or lawful need to keep your Personal Data, we will delete it.

Keeping each other informed

We will give you information about your portfolio(s) and provide regular statements. If we need to get in touch, we will call you or write to you by secure message. To make sure you can receive information and communications from us, please make sure you tell us whenever you change your name, address, phone number, email address or nominated bank account. You can update your details online through account management by visiting www.tillerinvest.co.uk and clicking “Account”.

Legal background and your rights

Here we summarise the lawful basis on which we collect and use your Personal Data and outline the rights you have under GDPR.

Lawful basis

The processing of Personal Data will only be lawful if it satisfies at least one of the following conditions:

  • Consent of the data subject (you)
  • Necessary for the performance of a contract with the data subject or to take steps preparatory to such a contract
  • Necessary for compliance with a legal or regulatory obligation, such as MiFID II
  • Necessary to protect the vital interests of a data subject or another person where the data subject is incapable of giving consent
  • Necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; or
  • Necessary for the purposes of legitimate interests.

We have a legitimate interest in promoting our services. For this reason, we may use your Personal Data to, for example, where explicit consent is given, send you marketing information about our own products or services that we think you may be interested in. You can ask us to stop sending you marketing and/or research at any time by clicking on the “unsubscribe” links in any of the electronic messages we may use for marketing purposes or amending your communication preferences in account management.

Your rights

Under certain circumstances, you have the following rights in relation to your Personal Data such as, the right to:

Access

You have the right to access Personal Data that we hold about you under GDPR by making a “Subject Access Request”. You can request the form from support@tillerinvest.com or by writing to us:  Subject Access Request, Tiller Investments Ltd, Charter House, 1/11 Carteret Street, London, SW1H 9DJ

Rectification

You have the right to ask us to rectify Personal Data we hold about you if it is inaccurate or not complete.

Erasure

You can request that we erase your Personal Data. We will keep basic data to identify you and retain it solely for preventing further unwanted processing.

Restricted Processing

You have the right to ask us to restrict how we process your data. This means we are permitted to store the data but not further process it. We keep just enough data to make sure we respect your request in the future.

Data Portability

Where processing is based on consent or performance of a contract, you have the right to data portability. We must allow you to obtain and reuse your Personal Data for your own purposes in a safe and secure way without this effecting the usability of your data. This right only applies to Personal Data that you have provided to us as the Data Controller.

Object to Processing

Where processing is based on legitimate interests, you have the right to object to us processing your data. We will discontinue processing your data, unless we can demonstrate compelling legitimate grounds for the processing. We will keep basic data to identify you and retain it solely for preventing further unwanted processing.

Right not to be subject to automated decision-making and profiling

If we have made a decision about you based solely on an automated process (e.g. through automatic profiling) that affects your ability to use the services or has another significant effect on you, you can ask to not to be subject to such a decision unless we can demonstrate to you that such decision is necessary for entering into, or the performance of, a contract between you and us. Even where a decision is necessary for entering into or performing a contract, you may contest the decision and require human intervention.

Cookie Policy

This site uses cookies to distinguish you from other users of our site.

What is a Cookie?

A cookie is a small file of letters and numbers which asks permission to be placed onto your computer’s hard drive. Once you have accepted a cookie the file is added to the hard drive of your computer. Cookies help analyse web traffic and lets web applications respond to you as an individual. Web applications can tailor their operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

Overall, cookies help us provide you with a better browsing experience, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

Use of Cookies

We implement the following type of cookies in our website:

Strictly necessary cookies

These cookies are essential to enable you to move around the website and use its features, such as accessing secure areas of the website.

  • Performance cookies

These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works.

We also use a common website analytics tool called Google Analytics which uses cookies similar to performance cookies, which gather and review analytic data such as number of site visits, average session duration, referral sources, devices used to access the website and browsers used to access the website.

Further information on Google Analytics can be found at www.google.com/analytics.

  • Functionality cookies

These cookies allow the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features.

  • How to control Cookies

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. Disabling or blocking may prevent you from taking full advantage of websites, including ours. When deleting cookies, please be aware that cookies that are already stored on your computer will not be affected. For that reason, you might want to delete the cookies already stored on your computer before deleting cookies on your browser. Our site relies on cookies to function properly – you will not be able to use our websites properly unless you accept our cookies.

Links to Third Party Websites or Other Services

Our site may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over these other websites. Tiller cannot be responsible for the protection and privacy of any information which you provide whilst visiting such websites and such websites are not governed by this Policy. You should exercise caution and we encourage you to review the privacy policy applicable to the website in question.

Significant Changes

From time to time we may update this Policy. You can see the latest version at www.tillerinvest.co.uk. If we make a significant change to how we use your Personal Data, we will let you know in advance.

Contact us

Tiller Investments Ltd is the Data Controller of the Personal Data we hold about you. If you have questions about this Policy, or need further information about our privacy practices, please write to us at: Data Controller, Tiller Investments Ltd, Charter House, 1/11 Carteret Street, London, SW1H 9DJ

If you wish to raise a complaint about how we have handled your Personal Data, you can contact us and we will investigate the matter. Please write to us at: Data Protection Complaints, Tiller Investments Ltd, Charter House, 1/11 Carteret Street, London, SW1H 9DJ

If you are not satisfied with our response you can complain to the Information Commissioner’s Office (“ICO”) at www.ico.org.uk.

Date of Issue: 25th April 2019

Tiller Investments Ltd is authorised and regulated by the Financial Conduct Authority (Firm Ref No 793479).
Tiller Investments Ltd is a limited company registered in England and Wales (Company No 10234817).

Copyright © Tiller Investments Ltd. All rights reserved.