This Privacy Policy governs the collection and use of personal data by Arden Partners plc in relation to the use of our website, or when we are provided with your personal data directly by you, the company that you represent or by a 3rd party. For more information about us, please visit www.arden-partners.com
To find out more about cookies, including what cookies have been set and how to manage and delete them, please visit https://www.allaboutcookies.org
This Privacy Policy explains the types of personal data we collect; how we use that information; who we share it with; how we protect that information; and your legal rights.
Any References to “our”, “us”, “we” or “Arden” within this Privacy Policy means Arden Partners plc and its subsidiaries, as applicable.
Please read this Privacy Policy carefully as it explains Arden’s behaviours regarding your personal data.
For the purpose of applicable data protection laws, the Registered Data Controller is Arden Partners plc, 5 George Road, Edgbaston, Birmingham, B15 1NP with registered number 04427253
How we collect your information
This Privacy Policy covers all personal data collected and used by us in relation to your use of our website, and in other ways, you (or a person on your behalf) interact with us, such as when we are supplied with your business contact details. In this Privacy Policy, “personal data” means information that (either individually or in combination with other available information) enables you to be identified as an individual or recognised directly or indirectly. This may include your name, company name, postal address, email address, phone number, where you are based or obtaining our products or services from, details of the preferences you express to us, your comments and questions, and technical information from the devices you use to access our website.
The information you have provided us with
Arden may collect personal data (such as your name, postal and email address, telephone and fax number, company, preferences, comments and questions) from you when you:
- obtain products or services from us, typically in your capacity as a representative of your company;
- submit any information to us in a written form;
- create an account, engage in a transaction with us or sign up for a service;
- are included in a distribution list supplied by the company that you represent;
- communicate with us on a recorded telephone line or via social media; contact us, correspond with us, or otherwise provide information to us; or
- contact us, correspond with us or otherwise provide information to us; or
- have your information supplied to us, typically in your capacity as a representative of your company.
On occasion, you may provide personal data to Arden about another person. You should only provide such information if you have the authorisation of the person to provide us with this information and for us to use this information as explained in our Privacy Policy.
3rd party and publicly available sources
Arden may, on occasion, work closely with 3rd parties (including analytics providers, search information providers and regulatory and industry participants or bodies), and may receive demographic and other personal data about you from those 3rd parties, which we may combine with the information you have provided to us. We process all data we obtain from such other sources in accordance with this Privacy Policy.
Website usage information
When you visit the Arden website, we (and our service providers) may use cookies and other technologies to automatically collect the following information:
- technical information, including your IP address, your login information, browser type and version, device identifier, location and time zone setting, browser plug-in types and versions, operating system and platform, page response times and download errors;
- information about your visit, including the websites you visit before our website and the components of our website you viewed during your visit
- the number of visits, length of visits to certain pages, pages viewed, page interaction information (such as scrolling, clicks and mouseovers) and methods used to browse away from the page; and
similar information for additional content that can be accessed from website pages, such as opening or printing pages or documents.
How we use your personal data
We use the personal data we collect from and about you for a variety of purposes and based on one or more legal justifications, as set out below:
| Purpose | Information | Justification | ||||
| To ensure that content on our website is presented to you in the most effective manner for your computer. |
We will collect and process certain personal data (such as details of your device, IP address and website usage information) to ensure that content from our website is presented in the most effective manner for you and your computer. | It is in our legitimate interests to process personal data in order to provide you with an effectively presented website. | ||||
| To provide the company you represent (or you directly) with requested products or services, including potential screening and background checks as to the company’s representatives, and subsequent relationship management. |
We require certain personal data to provide the company you represent (or you directly) with requested products or services, including the performance of certain background checks. | Processing is necessary for the purposes of complying with legal requirements to which we are subject, performing our contractual obligations, and/or responding effectively to your requests as part of our legitimate interests. | ||||
| To deal with your queries and requests, including to identify you when you contact us. | We will need to use your personal data (such as your contact details) to assist you with enquiries and requests and to identify you when you contact us. | It is in our legitimate interests to process personal data in order to provide you with an answer to your queries and requests and to meet our service obligations. | ||||
| To notify you about changes to our services | We may need to process your personal data (such as your contact details) to notify you about changes to our services. | It is in our legitimate interests to process your personal details in order to notify you of changes to our service. In some instances, we may need to process information in this way to comply with laws that require us to notify you about changes in our services. | ||||
| To engage or transact with you in relation to the products and services that Arden provides. | We may need to process your personal data in the execution of a transaction involving one or more of Arden’s products or services. | Processing is necessary for the purposes of complying with legal requirements to which we are subject, performing our contractual obligations, and/or responding effectively to your requests as part of our legitimate interests. | ||||
| To provide you with information about our products and services. | We will need to use your personal data (such as your email address or other contact details) to send you information about Arden’s products and services. | We will ask for your consent before processing your information in this way when required. In addition, we will give you the option to withdraw your consent (opt out), such as in each email marketing message we send. | ||||
| To design our products and services and to help us develop new services and products. | We may use your personal data to ensure that any new products and services we are developing best suit your needs. | It is in our legitimate interests to process personal data in order to more effectively design our products and improve our offering as a business. | ||||
| To help identify illegal activity. | We may need to use your personal data to identify and investigate illegal or fraudulent activity. | This processing is necessary for the purposes of complying with legal requirements to which we are subject and/or managing risks to which our business may be subject as part of our legitimate interests. | ||||
| To comply with our legal and regulatory requirements. | We may need to use your personal data to comply with other legal and regulatory requirements. | This processing is necessary for the purposes of complying with legal requirements to which we are subject. | ||||
| To process your personal data where this is necessary to keep our website safe and secure. | We may need to process your personal data in order to keep our websites safe and secure and protect against illegal or fraudulent activity such as cyber-attacks. | It is in our legitimate interests to monitor how our websites are used to detect and prevent fraud, other crimes, and the misuse of our websites. This helps us to ensure that you can safely use our websites. In some instances, we may need to process information in this way to comply with laws that require us to keep our websites safe and secure. | ||||
| To keep internal records and manage our relationship with you. | We will keep records of your personal data, such as your name, address, account details and marketing preferences, in order to administer our services and products and keep our records up to date. | It is in our legitimate interest to keep records of your personal details and update these when necessary. It is also in our legitimate interests to keep records of any correspondence with you. Our customers are important to us and so we need to keep track of your details and preferences. | ||||
| To allow you to subscribe to our research products or other services you’re interested in, and to use this information to provide materials to which you have subscribed including email updates. | We will need to use your personal data (such as your email address or other contact details) to send you information about Arden’s products or services you’ve asked to subscribe to and so that we can provide you with personalised email experience. | It is in our legitimate interests to process personal data in order to provide you with a tailored answer to your queries and requests. | ||||
| To keep an up-to-date suppression list where you have asked not to be contacted. | We understand that you may prefer for us not to contact you with details of our products and services. We keep records of your preferences to ensure that we do not contact you if you have asked us not to. We may need to process and hold certain personal data (such as your name and email address) in order to do this. | It is in our legitimate interests as we, pursuant to good marketing practice, are obliged to process personal data to maintain an up-to-date suppression list and ensure that we do not contact you where you have asked us not to. |
When relying on the legitimate interest basis for processing your personal data, we will balance the legitimate interest pursued by us and any relevant 3rd party with your interest and fundamental rights and freedoms in relation to the protection of your personal data, to ensure it is appropriate for us to rely on legitimate interests and to identify any additional steps we need to take to achieve the correct balance.
The provision of your personal data is necessary when data is needed for the purposes of entering into or servicing a contract that you, or a company you are associated with, has with Arden, or to receive the products, services or information you or your company request, or to comply with any applicable laws and regulations.
Refusal to provide us with your information would make it impossible for us to provide the products, services or information requested, or to fulfil our contractual obligations.
Sharing your personal data
Your personal data is intended for use by Arden and may be shared with its subsidiaries, affiliates and 3rd parties under certain circumstances.
Our website may, from time to time, contain links to and from the websites of our subsidiaries, affiliates and 3rd parties. If you follow a link to any of these websites, please note that these websites have their own privacy notices and that we have no control over how they may use your personal data. You should check the privacy notices of third party websites before you submit any personal data to them.
We may share your personal data with the following third-party organisations.
Cookie Policy
A “cookie” is a bite-sized piece of data that is stored on your computer’s hard drive. They are used by nearly all websites and do not harm your system.
We use them to track your activity to help ensure you get the smoothest possible experience when visiting our website but the information does not usually identify you directly. We can use the information from cookies to ensure we present you with options tailored to your preferences on your next visit. We can also use cookies to analyse traffic and for advertising purposes.
These also include social media plug-ins which enable you to share our website content via your social media account(s) or easily share information with others. We have a presence on YouTube, LinkedIn and Twitter, and if you click on any of these icons on our website, you will be taken to our pages or profiles on those platforms. The platforms may then start tracking your behaviour using cookies for their own purposes; for example, to better understand your interests so that they can present relevant content or advertising to you. Data about you may also be transmitted to the social media channel even if you do not click on the plug-in. The social media platforms will provide us with statistical information, which we use to help understand how you and our other users interact with our social medial presence. All these platforms provide you with some control over their use of non-essential tracking technology and you can find details of how to exercise this control by reviewing their privacy and cookie notices. We have contractual arrangements in place with the social media channels we use. Please contact us for more information.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.
Below we describe the cookies which are installed upon this website.
You can change your cookie preferences at any time by clicking on the icon at the bottom left of this webpage. You can then adjust the available sliders to “On” or “Off” and then click “Save and close”. You may need to refresh your page for your settings to take effect.
Alternatively, most web browsers allow some control of most cookies through the browser settings. Find out how to manage cookies on popular browsers:
If you use a smart phone, you can usually prevent cross-site tracking and block cookies in the settings section on your device. You may also be able to visit websites without leaving a history by turning private browsing on. You should visit the support section of the website of your device for more information on how to do this.
Strictly necessary cookies
These cookies are always active and are necessary for this website to function. They cannot be switched off. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences.
You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.
| FUNCTION PROVIDER | COOKIE NAME | DATA STORED | PURPOSE | DURATION |
|---|---|---|---|---|
| Youtube.com | LOGIN_INFO, 1p_JAR, ANID, APSID, CONSENT, DSID, GPS, HSID, SID, SSID, IDE, NID, OGP, OGPC, PREF, SAPISID, SID, SIDCC, SSID, VISITOR_INFO1_LIVE, YSC, permutive-id, permutive-session, watched_video_id_list, demographics | Various unique identifiers, as well as login information that may relate to a Google account. | Video functionality | Some of the cookies expire up to 20 years after your last visit to a page containing a Youtube video, although some expire sooner. |
| arden-partners.com | PHPSESSID | Works by creating a unique id (UID) for each visitor and stores variables based on this UID. | Session cookie | When browsing session ends. |
| moove_gdpr_popup | Cookie set by the UK cookie consent plugin to record that you accept the fact that the site uses cookies. | |||
| pum-* | These control the repeated display of popups in the browser. Cookies are assigned an identification (ID) number formatted as ‘pum-{integer}’. | 14 days | ||
| BrighterIR | AWSALB, AWSALBCORS | Cookie set by Amazon Web Services Load Balancer to preserve server session stickiness. | 1 week | |
| XSRF-TOKEN | Cookie set by Laravel framework to protect against cross-site exploits. | 2 hours | ||
| Laravel_session | Cookie set by Laravel framework to preserve session data on investor relations tools. | 2 hours |
Performance cookies
These cookies allow us to count visits and traffic so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular, and see how visitors move around the site.
All information that is collected by these cookies is aggregated, and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.
These cookies are set by the Google Analytics service, but hosted by Arden Partners.
| HOST | COOKIE NAME | DURATION |
|---|---|---|
| arden-partners.com | _ga | 1 year |
| arden-partners.com | _gat | 1 minute |
| arden-partners.com | _gid | 24 hours |
Targeting cookies
We do not currently use targeting cookies.
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 require further information please contact us by emailing mydata@arden-partners.com
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.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Subsidiaries of Arden Partners plc
We may share your personal data with our subsidiaries, in order to administer our products and services, provide you with support, understand your preferences, send you information about products and services that may be of interest to you, and conduct the other activities described in this PrivacyPolicy.
External Auditors & Lawyers
We may share your personal data with our auditors and legal advisers.
Competent Authorities
We may share your personal data with competent authorities including the FCA and HMRC.
Law Enforcement Agencies
We may share your personal data with relevant law enforcement agencies and other judicial bodies.
Our service providers
We may use other companies or contractors to perform services on our behalf or to assist us with the provision of Arden’s products or services to you.
We may share your personal data with the following categories of service provider:
- Infrastructure and IT service providers;
- Corporate events and hospitality providers (where you have accepted an invitation from us);
- Providers of administrative services for Arden’s products or services, including accountants, custodians, banks and securities’ pricing providers
- Connected parties, in the event that you have engaged with Arden in relation to a transaction involving one or more of our products and/or services.
In the course of providing such services, these service providers may have access to your personal data. However, we will only provide our service providers with the information that is necessary for them to perform the services, they will act under our instructions and we ask them not to use your personal data for any other purpose. We will always use our best efforts to ensure that all the service providers we work with will keep your personal data secure.
Your company and other 3rd parties connected with your company or its account
We may transfer your personal data to your company, such as when you are included in an email with others or to confirm your details or role with your company. We also may transfer your information to 3rd parties connected with your company or its accounts, such as a consultant used by your company or its trading partners.
3rd parties connected with business transfers.
We may transfer your personal data to 3rd parties in connection with a reorganisation, restructuring, merger, acquisition or transfer of assets, provided that the receiving party agrees to treat your personal data in a manner consistent with this Privacy Policy.
Storing your personal data
We use reasonable measures to safeguard Personal Data from theft, unauthorized use, disclosure, or modification. We aim to maintain appropriate physical, procedural and electronic safeguards to protect your Personal Data.
Your rights and freedoms
You have various rights in connection with our processing of your personal data, each of which is explained below. If you wish to exercise one or more of the below rights, please contact us with your request at mydata@arden-partners.com, and include your name, email and postal address, as well as your specific request and any other information we may need in order to provide or otherwise process your request.
The rights described below only relate to your personal data.
Access
You may have the right to confirm with us whether your personal data is processed, and if it is, to request access to that personal data including the categories of personal data processed, the purpose of the processing and the recipients or categories of recipients. We are required to consider the interests of others, so this is not an absolute right.
Rectification
You may have the right to rectify inaccurate or incomplete personal data concerning you.
Deletion
You may have the right to ask us to erase personal data concerning you. We are not obligated to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.
Restriction
In limited circumstances, you may have the right to request that we restrict the processing of your personal data. This may apply where you believe such data to be inaccurate, our processing is unlawful or that we no longer need to process such data for a particular purpose, but where we are not able to delete the data due to a legal or other obligation or because you do not wish for us to delete it.
Portability
You may have the right to ask to receive personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you may have the right to transmit that data to another entity.
Objection
Under certain circumstances, you may have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data.
Withdrawing Consent
If we are processing your personal data on the basis of your consent, you have the right to withdraw your consent at any time. If you would like to withdraw consent, including if you would like to opt out of receiving marketing correspondence from us, please contact us at mydata@arden-partners.com
If you opt out of or unsubscribe from receiving promotional correspondence from us, we may still contact you in connection with an account, relationship, activities, and other communications with us.
Make a Complaint
You also have the right to lodge a complaint with the UK Information Commissioner’s Office (the ‘ICO’).
Retaining your personal data
Arden will only retain your personal data for as long as it is necessary for the purpose for which that data was collected and to the extent permitted by applicable laws. When we no longer need to use your information, we will remove it from our systems and records and/or take steps to promptly anonymise it so that you can no longer be identified from it (unless we need to keep your information to comply with legal or regulatory obligations to which we are subject). The FCA stipulates that authorised firms must retain certain personal and sensitive information, provided by their clients for the purposes of providing investment services, for a specified period of time. This information may be retained by the firm in both digital and hardcopy form for the purposes of evidencing retention to the FCA.
Arden’s Data Retention Policy is to retain all client information (including any personal and sensitive data you have provided during the course of our relationship) in compliance with the maximum retention period as currently stipulated by the FCA. In practice, this means that Arden will retain your information for a minimum period of 7 years from the date that our relationship with you ends.
Storage of your information during the Retention Period
During the retention period, your information will continue to be available in our internal systems to enable Arden Staff to deal with any queries that you may have. Arden may decide to archive any hardcopy information you have provided at any time during the Retention Period. We are required to ensure that any physical archiving facilities comply with such data protection laws that may be in force from time to time.
Extension of the Retention Period
Arden may, from time to time, elect to retain some or all of your information for a period in excess of 7 years. We may elect to retain your information for longer than the 7 years specified in our Retention Policy for the following reasons:
- Regulatory changes require us to extend the Retention Period
- For the purposes of investigating a complaint
- To comply with a request from a competent authority (FCA / HMRC etc.)
- At our discretion, Arden elects to extend the Retention Period
- You ask us to retain your personal information
Deletion of your information
Subject to the Retention Period of your information not being extended, Arden will delete any personal and sensitive information that we hold (digital and hardcopy), retaining only such limited information that we require to establish that you have been, from time to time, a client of the firm.
We retain these limited records to ensure that you are not contacted by Arden in the event that you have exercised your right to be forgotten or withdrawn your consent to receive ongoing communications from Arden.
Security of your data
We have implemented technical and organisational security measures in an effort to safeguard personal data in our custody and control. Such measures we have implemented include, limiting access to personal data only to employees, contractors and authorised service providers who need to know such information for the purposes described in this Privacy Policy.
Changes to our Privacy Policy
We reserve the right to change our Privacy Policy from time to time. If we decide to make a material change to our Privacy Policy, we will endeavour to make you aware of that fact by, for example, notifying you of these changes via email and/or posting an alert on the home page of our website.
Contact us
If you have any questions in relation to this Privacy Policy or other data protection matters, please contact us via email at mydata@arden-partners.com
