Sharewatch Limited is a company registered in Dublin, Ireland No 286532 and is a "controller" of the personal information that you provide to us unless otherwise stated in this privacy notice.
Sharewatch Ltd is committed to protecting your privacy and maintaining the security of any personal information received from you. We strictly adhere to the data protection legislation in Ireland.
The purpose of this privacy notice is to explain to you what personal information we collect and how we may use it.
Collection of personal information
Through our website, we collect and use the following personal information about you:
· your name, email address, the reason you visit our website, whether you found the information you were looking for and any comments that you provide when submitting feedback through our online feedback form;
· your name, phone number and message when contacting us through our online form regarding email@example.com; and
· As an Investment Business Firm* (Investment Intermediaries Act 1995) we also collect and save personal information about you when providing an introduction to other investment business services.
· *An Investment Business Firm (Investment Intermediaries Act 1995). Sharewatch Ltd t/a Sharewatch.com is an Investment Business Firm authorised under Section 10 of the Investment Intermediaries Act, 1995 (as amended). An Investment Business Firm (Investment Intermediaries Act 1995) means any person, other than an Investment Firm (MiFID), who provides one or more investment business services or investment advice to third parties on a professional basis and for this purpose where an individual provides an investment business service and where that service is carried on solely for the account of and under the full and unconditional responsibility of an investment business, that activity shall be regarded as the activity of the investment business firm.
We may collect information about your computer, including, where available, your IP address, operating system, browser type and version, time zone setting and browser plug-in types and versions for system administration and to collate aggregate information. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.
We may also use analytical cookie files. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using them. This helps us to improve the way our website work, for example, by ensuring that users are finding what they are looking for easily.
You can find more information about the individual cookie files we use and the purposes for which we use them in the table below:
Cookie File Name
None at present
If you wish to delete any cookie files, please refer to the instructions for your file management software to locate the file or directory that stores cookies. Our cookies will contain the domain name sharewatch.com within the file name.
Uses of personal information
We need to collect our members' personal information so that we can manage your membership. We will use our members' personal information to:
· establish and manage your account within the regulated environment which prevails in Ireland and supply you with information regarding opportunities that we believe may be of interest to you;
· consider and respond to requests submitted through our website;
· send emails with a performance sheet and regular updates in relation to our activities;
· manage online accounts for clients to view performances;
· improve our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
· keep our website safe and secure; and
· insert any other uses of all other personal information.
We may ask you if we can process your personal information for additional purposes. Where we do so, we will provide you with an additional privacy notice with information on how we will use your information for these additional purposes.
Lawful basis for using personal information
When we use your personal information we are required to have a lawful basis for doing so. There are various different lawful bases upon which we may rely, and these will depend on the personal information in question and the specific context in which we collect it.
The lawful bases we may rely on include:
· consent: where you have given us clear consent for us to process your personal information for a specific purpose;
· contract: where our use of your personal information is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract;
· legal obligation: where our use of your personal information is necessary for us to comply with our law legal obligations or under law; or
· legitimate interests: where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal information which overrides our legitimate interests).
We will also process your personal information where required for public interest reasons (for example, fraud or crime prevention or detection) or in the event that we need to establish, defend or exercise legal claims.
Where we ask you for your consent to process personal information, you have a right to withdraw this consent at any time by contacting us at firstname.lastname@example.org.
Where we use your personal information for legitimate interests, you have a right to object to use of your personal information by contacting us at email@example.com.
Sharing of personal information
We may disclose your personal information to successors in title to our business and suppliers we engage to process data on our behalf to provide services, including [IT, etc.]. These suppliers may process personal information on our behalf as "processors" and are subject to written contractual conditions to only process that personal information under our instructions and protect it.
We do not sell, rent or exchange your personal information with any third party for commercial reasons. However, where required by law or regulation, your personal information may also be disclosed to an applicable governmental, regulatory or enforcement authority and where required to comply with statutory obligations and in accordance with data protection legislation.
We may also share personal information with our professional and legal advisors for the purposes of taking advice, as well as our auditors where required.
In the event that we do share personal information with external third parties, we will only share such personal information strictly required for the specific purposes and take reasonable steps to ensure that recipients shall only process the disclosed personal information in accordance with those purposes.
Protection of personal information
Your personal information is stored on our electronic filing system and our servers based in the Ireland/EU, and is accessed by our staff for the purposes set out above. In accordance with the data protection legislation, we follow strict security procedures in the storage and disclosure of information that you have given us, to prevent unauthorised access or use, damage or destruction to your personal information.
Retention and destruction of Personal Data
Your personal information will be kept securely by the Sharewatch for the period stated in applicable law and/or for as long as is required to perform our contract with you, after which it will be securely destroyed. We adhere to applicable Financial Conduct Authority regulations that require retention of certain financial information for a period of six years.
We may keep personal information longer where: (i) there is litigation or an investigation; (ii) where we are obliged to by any applicable law or regulation (iii) it may be required to assist with the mitigation of any future tax or regulatory query or enquiry into the transactions or other affairs undertaken by the Fund (iv) at your request (in which case there may be a charge).
You have a number of rights in relation to your personal information under data protection legislation as follows:
Right of access
You have the right to obtain confirmation that your personal information is being processed, what categories of personal information we process, where and to whom your information is transferred and why we process it. On request we will provide a copy of the personal information we hold on you free of charge.
For subsequent requests we may charge a fee based on the administrative costs of providing the information. Where requests are deemed to be manifestly unfounded or excessive (for example where requests are repetitive) we are entitled to either refuse the request or charge a reasonable fee based on the administrative costs of providing the information.
Right to restrict processing
You have a right to restrict the processing of your personal information where one of the following applies:
· you contest the accuracy of your personal information while we investigate the inaccuracy/update the information;
· the processing is unlawful and you oppose the erasure of your personal information and request the restriction of its use instead;
· you have objected to processing pending the verification whether the legitimate grounds of the controller override those of your own; or
· you may also request that we do not delete/destroy your personal information, even once we no longer need it, should you require it for the establishment, exercise or defence of legal claims.
Right to rectification
You have a right to have your personal information rectified if it is inaccurate or incomplete.
Rights in relation to automated decision making and profiling
You have the right object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affecting you. We do not utilise automated processing which produces legal effects for data subjects.
Right to object
You have the right to object, on grounds relating to your particular situation, to:
· processing based on legitimate interests, unless we can demonstrate compelling legitimate grounds for the processing, which override your interests, rights and freedoms or where the processing is necessary for the establishment, exercise or defence of a legal claim;
· direct marketing (including profiling); or
· processing for purposes of scientific/historical research and statistics.
Right to data portability
You may request us to either send you a copy or to transfer your personal information from one IT environment to another in a safe, easily usable and secure way. This right only applies where the processing is based either on consent or on the performance of a contract and the processing is carried out by automated means.
Right to erasure
You have a right to request the deletion or removal of your personal information where there is no compelling reason for its continued processing. It is not an absolute right and can be used in specific circumstances such as:
· where the personal information is no longer necessary in relation to the purpose for which it was originally collected/processed and there is no legal obligation on us to keep it;
· where you as the withdraw consent where the sole lawful basis for processing was consent;
· where you object to the processing and there is no overriding legitimate interest for continuing the processing;
· The personal information was unlawfully processed; or
· the personal information has to be erased in order to comply with a legal obligation.
Making a complaint to a regulatory authority
Any requests received by Sharewatch Limited will be considered under Irish data protection legislation. If you remain dissatisfied, you have a right to raise a complaint with the Information Commissioner's Office at www.dataprotection.ie
Data Protection Commission
R32 AP23 Co. Laois.
How to contact us
Please contact us at firstname.lastname@example.org if you have any questions about this privacy notice or the information we hold about you or wish to exercise any of the rights above.
Changes to this privacy notice
This privacy notice was published on 15th June 2000 and last updated on 5th June 2018.
We may update this privacy notice to reflect changes in the law or our privacy practice. Should you require further information please contact us at the above details.