Last updated: 25-May-18

Worthstone Limited (hereinafter referred to as “Worthstone”, “we”, “us” or “our”) operates the website, www.worthstone.co.uk (“Website”) and related services, including the Worthstone Impact Portal, Social Investment Academy and Adviser Competency Training (ACT) for social investment.This Privacy Policy explains how Worthstone, as data controller, collects, uses and shares your personal information, particularly in relation to our Website and services.

Collection of personal information

“Personal information” (also referred to as “Personal Data” in some jurisdictions) is any information that can be used to identify you or that we can link to you.

Information we collect from you

We collect, process and use the following personal information about you:

  • Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our service or requesting further services. We may also ask you for information when you report a problem with our Website
  • If you contact us, we may keep a record of that correspondence
  • We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them
  • Details of transactions you carry out through our Website and of the fulfilment of your orders
  • Details of your visits to our Website including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access
  • How you rate the products that are included in the database on the Website
  • Details of attendance at our Social Investment Academy.

The information we collect is typically related to the product or service you request and includes:

  • your name and title;
  • your address and email address;
  • the nature of the product or service requested;
  • information relating to payment;
  • related information so that we may fulfill your request; and
  • relevant company details (such as your FCA number).

If you choose not to provide certain key information, this may mean that we are not able to provide you with all of our services.

Cookies and similar tools

We use browser cookies and similar technologies (collectively, “cookies”) to collect and store certain information when you use, access or interact with our Website or services. A cookie is a small text file which is sent by a website, accepted by a web browser and then placed on your hard drive.

Our Website uses cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our Website and services. For further information, please see our Cookie Policy.

We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.

How we use the information we collect

We may use the information we collect:

  • to ensure that content from our Website is presented in the most effective manner for you and for your computer and to operate, troubleshoot, and improve our services;
  • to provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes;
  • to carry out our obligations arising from any contracts entered into between you and us;
  • to allow you to participate in interactive features of our service, when you choose to do so;
  • to notify you about changes to our service;
  • to respond to your inquiries;
  • to maintain our list of contacts;
  • to understand how people use our services, including by generating and analysing statistics;
  • for our business purposes, including data analysis; submitting invoices; detecting, preventing, and responding to actual or potential fraud, illegal activities, or intellectual property infringement;
  • to assess the effectiveness of our events, promotional campaigns, and publications; and
  • as we believe reasonably necessary or appropriate to: comply with our legal obligations; respond to legal process or requests for information issued by government authorities or other third parties; or protect your, our, or others’ rights.

How we may share the information we collect

We may share the information we collect, including your personal information, with third parties under the following circumstances:

  • Service providers and business partners. We may share your personal information with our service providers and business partners that perform marketing services and other business operations for us. For example, we may partner with other companies to process secure payments, fulfill orders, optimise our services, send newsletters and marketing emails, support email and messaging services and analyse
  • Protection of rights and other legal purposes. We may share the information we collect, including personal information, with any law enforcement agency, court, regulator, government authority or other third party where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise in order to enforce or apply any agreements; or to protect the rights, property, or safety of Worthstone, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
  • Asset purchases. We may share the information we collect, including personal information, with any third party that purchases, or to which we transfer, all or substantially all of our assets and business. Should such a sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your personal information uses it in a manner that is consistent with this Privacy Policy.

Data transfers from the EU

Your personal information may be transferred to, stored, and processed outside the European Economic Area (EEA) on third party provider’s servers. As of 24th May 2018, we have confirmed the compliance of these third parties to the EU-U.S. Privacy Shield in accordance with applicable legal requirements to ensure that your data is adequately protected. The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation. For more information on the appropriate safeguards in place, please contact us using the contact details below.

Legal bases for using your personal information

There are different legal bases that we rely on to use your personal information, namely:

  • Performance of a contract – The use of your personal information may be necessary to perform the contract that you have with us. For example, as a user of our services we will use your personal information to respond to your requests and provide you with such services.
  • Consent – We will rely on your consent to use (i) technical information such as cookie data and geolocation data as described in this Privacy Policy and our Cookie Policy; and (ii) your personal information for marketing purposes. You may withdraw your consent at any time by contacting us at the details at the end of this Privacy Policy.
  • Legitimate interests – We may use your personal information for our legitimate interests to deliver or improve our products and services and the content on our Website.

Third party websites

Our Website may contain links to websites not owned or controlled by Worthstone. Worthstone does not have any control over these third-party websites. We encourage you to be aware of these other third-party websites and their privacy statements, as we cannot control and are not responsible for privacy policies or practices of third party websites. Please check these policies before you submit any personal data to these websites.

This Privacy Policy applies solely to the information collected by Worthstone.

Security and data retention

We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorised access, alteration, disclosure or destruction of your personal information, username, password, and data stored through our services.

However, no information system can be 100% secure.  So, we cannot guarantee the absolute security of your information.  Moreover, we are not responsible for the security of information you transmit to us over networks that we do not control, including the Internet and wireless networks.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

We will keep your personal information for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your personal information for a period of time that enables us to:

  • maintain business records for analysis and/or audit purposes;
  • comply with record retention requirements under the law;
  • defend or bring any existing or potential legal claims; and
  • deal with any complaints regarding the services.

We will delete your personal information when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.

Your choices and your rights

You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at info@worthstone.co.uk.

Subject to local law, you may have certain rights regarding information that we have collected and that is related to you. We encourage you to contact us to update or correct your information if it changes or if you believe that any information that we have collected about you is inaccurate.

Consistent with legal requirements and limitations, you can also ask us:

  • to see what personal information we hold about you;
  • to erase your personal information;
  • to port your personal information; and
  • to restrict our use of your personal information.

Please note that we will likely require additional information from you in order to honour your requests.

If you would like to discuss or exercise such rights, please contact us using the contact details below. Alternatively, you may have a right to complain to your local data protection authority (if one exists in your country).

Changes to this Privacy Policy

We may update this Privacy Policy from time to time.  The effective date of the current Privacy Policy is noted at the top of this page. We encourage you to periodically review this page.

How to contact us

Questions, comments and requests regarding this privacy policy or our privacy or data protection practices are welcomed and should be addressed to info@worthstone.co.uk.