Information that identifies or can be used to identify a living individual is known as "personal data." All organizations processing personal data must do so fairly and in accordance with all applicable data protection laws. This includes the obligation for us to tell you how we will use your personal data. We treat all of our legal obligations seriously and take all steps necessary to ensure compliance when storing and processing your personal data.

We retain and use your personal data for some or all of the following purposes:
Security, payment verification, insurance, debt tracing and debt recovery;
Dealing with any queries, complaints or problems reported by you;
Enabling you to participate in our promotions and competitions;
Enabling you to participate in the interactive features of the website and ensuring content from our website is presented in the most Effective manner for you and your computer or device;
Notifying you about changes to our service and/ or the terms on which the services are provided;
To ensure the proper operation of our systems;
To keep our client records up to date;
To better understand your requirements and provide you with services specific to your needs;
To comply with applicable laws where we are obliged to retain and/or disclose certain information;
Generating statistics on our users, such as the popularity of our certain services and about the "traffic" visiting our websites in order to improve our services to you; and/or
To provide you with information about goods or services we feel may interest you in accordance with applicable laws (please see further details on our marketing activities at section 6 below).
Automated Decisions
As part of our account-opening process we will carry out automated checks using your personal data, such as your name, postal address, date of birth, telephone numbers and employment status. These checks include credit checks, identification verification checks and financial crime checks and involve our obtaining information (such as your credit history) from credit reference agencies and any records held by financial crime prevention agencies, the Electoral Register, and providers of utility services. We need to carry out these checks in order to meet our obligations ‘Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017’ (the MLRs) and any other applicable legislation. The information obtained from these checks is used by us (together with information provided by you in your application) to build a ‘scorecard’ relating to the applicant which is used to determine if an account can be opened, whether further information is required or the application is rejected, based on factors such as whether we have been able to verify your identity and any records relating to financial crime. We will process all such information in accordance with applicable data protection laws.

We will only keep your personal data for as long as we need to in order to fulfil the relevant purpose(s) it was collected for, as set out above in this privacy policy and for as long as we are required to keep it by law. We retain copies of our customer contracts in order to enable us to deal with any legal issues along with the information provided to us for identification verification checks and anti-money laundering checks (as required by law) for 5 years after termination or expiry of our contract with you. Details of complaints are retained for 5 years from receipt in accordance with the DISP chapters of the FCA Handbook and telephone call recordings are retained for five years or longer if required by law or the FCA. If you have a query in relation to how long we retain your personal data for, please contact us using the contact details provided below.

Whenever we collect or use your personal data, we will make sure we do this for a valid legal reason which will generally include at least one of the following reasons:
Because it is necessary to fulfil the terms of our contract with you;
Because it is necessary to support the legitimate interests of our business or the legitimate interests of others. Whenever we use this legal basis, we will undertake a balancing test to ensure that our legitimate interests are not outweighed by your personal interests or fundamental rights and freedoms which require protection;
Because it is necessary to fulfil a legal obligation; and/or
Where we have obtained your consent – we will always make it clear when we need your consent and how you can change your permissions and/or withdraw your consent at any time thereafter.
If you would like to know more about our legal basis for using your personal data in any particular way, you can contact us at any time using the details at section 13 below.

We (or a third party acting for us) may use the information you provide us with to keep you informed about products and services which we believe you may be interested in, carry out market research and/or to review how you use your account in order to maximize customer engagement and assess customer satisfaction. This information may be sent to you by e mail, SMS, other electronic means, telephone and/or post.
In most cases, we will only conduct such marketing activities where we have obtained your consent, a third party has obtained consent on our behalf or otherwise in accordance with applicable laws. Depending on the nature of the consent collected, we (or a third party acting for us) may carry out targeted electronic marketing based on, for example, location or profiling data.
In some circumstances, we may rely on a provision contained in Article 22 (3) of the ‘Privacy and Electronic Communications (EC Directive) Regulations 2003’ (PECR). This is also known as the ‘Soft Opt-In’. You can find out more about it on the ICO website, here:
https://ico.org.uk/for-organisations/guide-to-pecr/electronic-and-telephone-marketing/electronic-mail-marketing/#softoptin; and
https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data- protection-regulation-gdpr/legitimate-interests/when-can-we-rely-on-legitimate-interests/
In summary, the Soft Opt-In allows a business send direct marketing providing it has obtained the contact details of the recipient in the course of establishing a service relationship (or the sale of a product), the marketing is in respect of similar products and services and the legitimate interests balancing test set out in section 5 is met.
In such circumstances, we will provide you with a simple means of opting-out of such marketing at the time that we collect your contact details and in any subsequent communications.
The Soft Opt-In cannot be used to promote third party products and services.
If you do not want to receive any marketing communications from us, you can unsubscribe when we initially obtain your details, or by contacting us in writing at any time or by opting out by following the opt out instructions on our website or app or contained in the relevant telephone, SMS, other electronic means, post, or email marketing communication.
Please note that your opting out of marketing communications will not prevent us from continuing to communicate with you as necessary to manage your account (such service messages may include, for example, where we consider it suitable or proper, in the circumstances, to make you aware of economic matters which may require your attention, and that you may otherwise have been unaware). Please refer to www.targetcap-assets.com for details of our products and services. Any such opt-out requests will not affect the running of your existing account or the services you request from us, in respect of which we will still process your personal data in accordance with this policy.

If you apply to open an account with us or where you apply for additional services, we will make searches about you at credit reference agencies who will supply us with credit information, as well as gathering information from the Electoral Register and providers of utility services for the purposes of credit risk reduction – these checks will include but will not be limited to ID verification and anti-money laundering checks. You are obliged to provide us with the personal information which we need to carry out these searches. If you object to us carrying out these searches, we will not be able to provide you with the services you requested from us. The agencies will record details of the search whether or not your application with us proceeds. We may make periodic searches of our records and those of Group companies, credit reference and financial crime prevention agencies, to manage your account with us (including but not limited to enabling the repatriation of lost assets where possible). We and other organizations who may be from other countries may access and use the information recorded by financial crime prevention agencies.
We may give details of your account and how you manage it to credit reference agencies. If you do not repay sums due in full and on time, we may tell credit reference agencies who will record such details.
To prevent or detect financial crime, or to assist in verifying your identity in order to fulfil our legal obligations, we may make searches at financial crime prevention agencies. We may also pass information to financial and other organizations involved in financial crime prevention to protect ourselves and our customers from theft and fraud. If false or inaccurate information is provided and financial crime is identified or reasonably suspected, details will be passed to financial crime prevention agencies who will record this. Law enforcement agencies may access and use this information. We, other Group companies, and other organizations may also access and use this information to prevent financial crime, for example, when:
Checking details on applications for credit, credit related services or other facilities;
Managing credit and credit related accounts or facilities;
Recovering debt;
Checking details on proposals and claims for all types of insurance; or
Checking details of job applicants and employees.
We will process all such data in accordance with applicable data protection laws but please note that:
We may disclose some of your personal information to third parties, the court service, regulators, or law enforcement agencies in connection with enquiries, proceedings, or investigations by such parties anywhere in the world or in order to enable us and other relevant Group companies to comply with their regulatory requirements or dialogue with its regulators as applicable; and
International regulations regarding the automatic exchange of information require financial institutions to collect and report certain information about an individual’s tax residency. We may be legally obliged to pass on your personal information to tax authorities who may, under inter-governmental agreements, exchange this information with tax authorities in other jurisdictions.
You have a right of access to your personal records held by credit reference and financial crime prevention agencies.
The identities of the credit reference agencies we use, their role, the data they hold, the ways in which they use and share personal data, data retention periods and your data protection rights are explained in more detail on their respective websites:
TransUnion - Credit Reference Information Notice (CRAIN) | TransUnion UK, LU, US, AU and 70 other countries
Equifax - Credit Reference Agency Information Notice (CRAIN) | Equifax UK, LU, US, AU AND 70 other countries
Experian - Credit Reference Agency Information Notice (CRAIN) | Experian
Please contact our Data Protection Officer using the details at section 13 below if you want to receive details of the relevant financial crime prevention agencies.

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You acknowledge that we may disclose your personal data to:
Entities within our Group;
Law enforcement bodies and/or other regulatory entities in order to comply with any legal obligation;
Third parties who we use to carry out the checks that we need to carry out on you, such as identification verification,
account verification, anti-money laundering checks, including financial crime prevention agencies and utility companies, and as specified in the terms of service;
Other parties who help us to deliver the services to you who may be located in or outside the US or European Economic Area (EEA);
Third parties for marketing purposes subject to the limitations set out in section 6;
Third parties who we partner with for the provision of our shareholder voting service (subject to you meeting our eligibility criteria for the service from time to time). Your personal data will be processed by these parties only to the extent necessary for the provision of the shareholder voting service. You can opt out of this service at any time by changing the settings in the Personal Details and Preferences section of your online account; and
Your employer (or the employer of a person who you are connected to) and/or an agent designated by your employer, if required by law or regulation which the relevant employer is subject to and you have consented to such data sharing.
For account verification, we use a third party supplier, TransUnion. You can find Transunion’s privacy policy at the following link: https://www.transunion.co.uk/legal-information/bureau-privacy-notice.
Third parties who we share your personal data with may only use it for the purposes set out in this policy and in accordance with all applicable laws.
If we transfer your data outside of the UK or EEA, we will always ensure that appropriate controls are in place to protect your data in accordance with applicable data protection laws.
For details of the potential transfers of or access to your personal data within or outside of the UK or EEA and the safeguards that we have in place when transferring, or allowing access to, your personal data, (and for a copy of the safeguards, where applicable) please contact our Data Protection Officer via email at dataprotection@targetcap-assets.com or using the postal address given at the end of this policy.
Your information may also be collected and used by any of the parties detailed in this section.

We take all reasonable care in the collection, storage, processing and disclosure of your personal data and have implemented internal security procedures to minimize the risk that unauthorized parties will be able to access and misuse the information. It is because of these security procedures that we may ask for proof of identity before we disclose any personal information about you.
For more information and top tips please visit our security update.

In the event that we are sold (fully or partially), integrated with another business or dispose of our rights and obligations under any agreement with you, your records may be disclosed under appropriate confidentiality terms to our advisers and any prospective purchaser’s adviser, and will be passed onto the new owners in accordance with all applicable laws.
In the event that we buy any business or assets, we may disclose your personal data to the prospective seller of such business or assets under appropriate confidentiality terms and in accordance with all applicable laws.

Please bear in mind that this policy only applies to websites and services operated by us and not those operated by third parties, including those to which our websites may link. We suggest that you make yourself familiar with any privacy policy provided by such third- party websites before providing personal information about yourself.

Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to your personal information, as follows:
To ask us not to process your personal data for marketing purposes;
To access personal information held about you and to obtain a copy of it (Please note: If you require information about your account and/or about any services we have provided to you, please contact our Customer Services team in the first instance. In most cases, we should be able to provide the information you require, and this will typically be quicker than submitting a Data Subject Access Request (DSAR));
To prevent any processing of a record of personal data that is causing or is likely to cause unwarranted and substantial damage or distress to you or another individual;
To obtain the rectification or completion of records of personal data which are inaccurate or incomplete;
To restrict or object to the processing of your personal data and to request its erasure under certain circumstances.
Please note that we will not be able to erase personal data where we have a legal obligation to retain such data or if we need to hold onto such data for other legitimate purposes e.g. defending any potential legal claim. In most cases, this means that we need to retain all or some of your personal data for 6 years after the closure of your account with us;
In certain circumstances, to request that the personal data which you have provided to us, be transmitted to another data controller in a structured, commonly used, and machine-readable format without hindrance, where technically feasible;
To obtain a copy of personal information safeguards used for transfers outside your jurisdiction;

If you have any queries about this policy or our use of your personal data, please contact our Data Protection Officer at our online support or in writing at:
info@targetcap-assets.com

Interactive Investor
If you have any queries about any of our terms of service documents or the website in general, do not hesitate to contact us at:
247 online Customer Services

Interactive Investor
Tel:

If you have any concerns or complaints as to how we have handled your personal data you may lodge a complaint with the UK’s data protection regulator, the ICO, US DATA who can be contacted through their website.