Aeon Investments Limited and its parent Aeon Group Limited and other affiliated entities located inside and outside the United Kingdom and the European Union (“Aeon”, “we”, “us” or “our”) respect your privacy and seek to protect your personal data.
The following information describes how we gather and use your personal data. The amount of information we hold on you and how we use it depends on your relationship with us and some of the sections below may not be relevant to you.
What we collect
- your name;
- your contact information such as your address, email address and telephone number;
- if you enter into a transaction with us, your payment details i.e. your bank name, account number and sort code;
- when browsing our site, your IP address, your browser type and language;
- information related to your attendance of, and interest in, our events and services;
- information about you that you give us in person by corresponding with us by phone, e-mail or otherwise;
- information in relation to your use of our services; and
- data provided by cookies and other similar technologies, functional data such as registration and system data, as well as additional usage data.
What we do with the information we gather
- We use your data to respond to your enquiries and provide you with information that we believe you would like to receive about us.
- We use your data to complete transactions with you, to provide the services you have engaged us to provide, to issue invoices and to collect payments.
- We use your data to communicate with you, for example, informing you about new transactions or events.
- We use your data to comply with legal and regulatory obligations.
- We apply appropriate security mechanisms to protect your personal data.
Legal basis for processing
Our processing of your personal information is necessary:
- for the performance of contracts to which you will be a party and in order to take steps at your request prior to you entering into those contracts;
- for the purposes of legitimate interests pursued by us; or
- in order to comply with a legal obligation to which we are subject.
In relation to any processing of special categories of personal data, we will generally rely on obtaining specific consent from you at the time unless there is otherwise a legal requirement for us to process such information.
Legitimate interests
Where our processing is based on the legitimate interest grounds described above, those legitimate interests are: (i) collecting personal information to provide you with a professional client experience; (ii) to make sure you receive updated information on our business activities; and (iii) to provide the services you have requested.
Sharing your information
Except as expressly set out in this policy we will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so.
The personal information you provide to us may be shared with third party companies, agents, contractors, service providers or affiliated companies if this is necessary to provide you with our services, respond to your inquiries or for any of the purposes described in this policy.
We may also share your personal information with:
- law enforcement agencies, other governmental agencies or third parties if we are required by law to do so; and
- other business entities should we plan to merge with or be acquired by that business entity, or if we undergo a re-organisation with that entity.
Transferring your information outside europe
Your personal information may be transferred to, held by and/or stored at a destination outside the European Economic Area (“EEA”). This may be to or by third parties or it may be to or by us or our affiliates. It may also be processed by our staff operating outside the EEA who work for us, or for one of our affiliates or service providers.
When we, or our permitted third parties, transfer or hold your information outside the European Economic Area, we or they will impose obligations on the recipients of that data to protect your information to the standard required in the European Economic Area or otherwise require the recipient to subscribe to international frameworks intended to enable secure data sharing. In the case of transfers by us, we may also transfer your information where:
(i) the transfer is to a country deemed to provide adequate protection of your information by the European Commission; or
(ii) where you have consented to the transfer.
Your rights
At any time, you have the right:
- to request access to or a copy of any personal data which we hold about you;
- to rectification of your personal data, if you consider that the information we are holding is inaccurate;
- to ask us to delete your personal data, if you consider that we do not have the right to hold it;
- to withdraw consent to our processing of your personal data (to the extent such processing is based on previously obtained consent);
- to ask us to stop or start sending you marketing messages as described below in the marketing section;
- to restrict processing of your personal data;
- to data portability (moving some of your personal data elsewhere) in certain circumstances;
- to object to your personal data being processed in certain circumstances; and
- to not be subject to a decision based on automated processing and to have safeguards put in place if you are being profiled based on your personal data.
Any request from you for access to or a copy of your personal data must be in writing and we will endeavour to respond within a reasonable period and in any event within one month in compliance with data protection legislation. We will comply with our legal obligations as regards your rights as a data subject.
We aim to ensure that the information we hold about you is accurate at all times. To assist us in ensuring that your information is up to date, do let us know if any of your personal details change at the following email address: compliance@aeoninvestments.com.
Marketing
Where you are one of our clients or have otherwise agreed to be contacted for marketing we may use your personal information to send you information about our services or events. You can unsubscribe from receiving them at any time, details of how to unsubscribe will be included on each electronic mailing we send you.
You also have the option of “unsubscribing” from our mailing list at any time thereby disabling any further such e-mail or other communication from being sent to you. You can do this by clicking on the unsubscribe button on our emails and on our website.
We will action any opt out request from you without delay.
How long will we keep your information?
We will only keep the information we collect about you for as long as required for the purposes set out above or as required to comply with any legal obligations to which we are subject. This will involve us periodically reviewing our files to check that information is accurate, up-to-date and still required.
Where we are permitted to send you direct marketing communications we may retain your contact information necessary for this purpose, for as long as you do not unsubscribe from receiving the same from us. If you opt out from marketing, we will retain your information to enable us to respect your wishes to not be contacted for marketing purposes.
Security
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
Links to other sites
Our website may contain links to other sites, including via our social media buttons. While we try to link only to websites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other websites and a link does not constitute an endorsement of that website. Once you link to another website from our website you are subject to the terms and conditions of that website, including, but not limited to, its internet privacy policy and practices. Please check these policies before you submit any data to these websites.
Certain features of our site will allow for social networking. You should ensure when using these features that you do not submit any personal data that you do not want to be sent, collected or used by other users, such as profile details or e-mail address.
Complaints
Questions, comments and requests regarding this policy are welcomed and should be addressed to:
E: compliance@aeoninvestments.com
A: Aeon Investments, 3rd Floor, 58 Davies St, London W1K 5LP
T: + 44 20 7046 7860 (request the Head of Compliance)
You may be entitled to make a complaint to the Information Commissioner’s Office, which regulates and supervises the use of personal data in the United Kingdom, via their helpline on 0303 123 1113.
How we use cookies
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site.
We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system
A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
Changes to this policy
Any changes we make to our policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our policy.