This data protection disclosure will explain how Iguana Investments (and our “Client Systems”) protects the personal data we collect from you (a “Client” and “User”) when you use our website and services. Iguana Investments may collect, process, transfer, store and use: (i) personal data in relation to and provided by Users, such as name, job title, contact details and summary business information; (ii) information concerning User access to Client Systems (such as when and how the services are used and technical details of Users’ connections, including Users’ IP addresses).
Iguana Investments will use the Information for (a) the purposes of providing the Services and (b) monitoring usage and improving the usefulness of Client Systems to Users.
Information is kept on Microsoft 365 and Zoho servers located in the UK, Europe and the US. Information is retained for a period of 5 years after the creation/receipt of such Information, unless otherwise required under applicable laws.
You agree to the use of the Information for the purposes set out below.
Client Consent: Iguana Investments may share the Information within Iguana Investments and hereby waives any protection of Information as provided for by applicable banking secrecy and client confidentiality rules and regulations, including consent to provide relevant authorities or governmental bodies with access to Information based on applicable laws and regulations.
User Consent: User consents to the collection, processing, transfer and storage of the Information for the purposes, retention times and access rights outlined above.
How do we collect your data?
You directly provide Iguana Investments with most of the data we collect. We collect data and process data when we contact or otherwise interact with you, for example if you provide us with a business card, agree to us retaining your information via email or voluntarily complete a survey or provide feedback.
We do not indirectly receive any data about you, and will only retain contact details collected in interactions with our company.
How do we store your data?
Our Company securely stores your data in a central contact databases within Zoho CRM and within our cloud servers provided by Microsoft. Our Company will keep your data for the duration of time that you are a client or prospective client of the firm, after which we will store contact details for up to five years. This time period is driven by the regulatory need to retain records of customer contacts. Once this time period has expired, we will delete your data.
How will we use your data?
Our Company collects your data so that we can remain in contact with you as a client or prospective client to exchange information about funds and more generally in order to facilitate the management of any funds associated with your business.
We will not share any data we hold with any other companies.
Transfers of Personal Information Across National Borders
Your personal information may be processed in countries outside the United Kingdom (“Third Country”), that may not offer the same level of data protection as that afforded by the UK General Data Protection Regulation (“GDPR”). Where we transfer your personal information outside of the UK, we will ensure that it is protected and transferred in a manner consistent with legal requirements applicable to the information. This can be done in a number of different ways, for instance:
- the Third Country to which we send the personal information may be approved by the Information Commissioner's Office;
- the recipient may have signed a contract based on “model contractual clauses” approved by the Information Commissioner's Office, obliging them to protect your personal information and we may have completed a risk assessment satisfying ourselves that those clauses provide you with protection that is sufficiently similar to the protections you are afforded when your personal information is in the UK; or
- In other circumstances, the law may permit us to otherwise transfer your personal information outside the UK. In all cases, however, any transfer of your personal information will be compliant with applicable data protection law.
What are your data protection rights?
Iguana Investments would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:
- The right to access – You have the right to request the Company for copies of your personal data.
- The right to rectification – You have the right to request the Company to correct any information you believe is inaccurate. You also have the right to request the Company to complete the information you believe is incomplete.
- The right to erasure – You have the right to request that the Company erases your personal data, under certain conditions.
- The right to restrict processing – You have the right to request that the Company restricts the processing of your personal data, under certain conditions.
- The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.
- The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email: email@example.com
How to contact us
How to contact the appropriate authority
Should you wish to report a complaint regarding privacy or data protection or if you feel that we have not addressed your concern in a satisfactory manner, you may contact the Information Commissioner’s Office (https://ico.org.uk/make-a-complaint/)