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Bonham Coutts

Legal

Privacy notice.

Template wording. Have it reviewed by a data protection adviser and completed with your ICO registration number before go-live.

Who we are

Bonham Coutts Ltd, trading as Sterling Gold Securities, is the data controller. Company number 17377911, registered in England and Wales. Registered office: [registered office address]. We are registered with the Information Commissioner's Office under registration number [•].

What we collect and why

  • Investor statement data — your name, email, the conditions you confirmed and the figures you gave. Lawful basis: legal obligation and legitimate interests, namely evidencing that a financial promotion exemption was properly relied upon.
  • Enquiry data — what you send us when you contact us. Lawful basis: legitimate interests in responding to you.
  • Marketing data — your email if you opt in to updates. Lawful basis: consent, which you may withdraw at any time.
  • Technical data — pages visited and device information, where you accept analytics cookies. Lawful basis: consent.

Marketing

We only send marketing by email where you have consented, or where the narrow soft opt-in under the Privacy and Electronic Communications Regulations applies. Every message carries an unsubscribe link and we act on it promptly.

We do not buy marketing lists, and we do not use data scraped from public registers to send financial promotions to individuals.

How long we keep it

  • Completed investor statements and the promotions they relate to: six years, as compliance records.
  • Enquiries: two years from your last contact with us.
  • Marketing consent records: for as long as you remain subscribed, plus two years.

Sharing

We share personal data with our hosting and email providers, our compliance adviser, and our section 21 approver where one is engaged. Each acts under a written contract. We do not sell personal data.

Where an investee company needs your details to issue shares or a tax certificate, we tell you before that happens.

Your rights

  • Access a copy of the personal data we hold about you.
  • Have inaccurate data corrected.
  • Have data erased, where we are not required to retain it as a compliance record.
  • Object to processing based on legitimate interests, and withdraw consent to marketing at any time.
  • Request portability of data you provided to us.
  • Complain to the Information Commissioner's Office at ico.org.uk.

Contact: investors@bonham-coutts.co.uk. UK GDPR · Data Protection Act 2018 · Privacy and Electronic Communications Regulations 2003.