Introduction
Your privacy and keeping your personal information secure are extremely important to us. At STL Asset Management Limited (STLAM), we are committed to protecting and respecting your privacy and handling your information openly and transparently. This Privacy Policy (“Policy”) explains among other things: what we do with your personal information; what we do to keep it secure;  with whom we share your information; your rights about the personal information we hold about you; and who you can contact for more information.

We will amend or update this Policy regularly to reflect changes in our practices concerning the processing of personal information, or changes in applicable law. We encourage you to read this Policy carefully and to regularly check this page to review any changes we might make to the terms of this Policy. STLAM will not sell, rent, or otherwise disclose your information to third-party marketers or others unaffiliated with STLAM for advertising, promoting, or selling other services to you.

Collection of Personal Data

STLAM first collects information about you as our client from the data you supply on the 1Click by STL application (the “App”). When you provide information to STLAM, through the App or otherwise, you are warranting to STLAM that all the information you provide to us about yourself is accurate and complete. STLAM relies on your warranty when STLAM provides the services to you. The information you provide includes personal data, which is defined as information that can be used, on its own or with other information, to identify you.

We may collect, record, and use information about you in physical and electronic form and will hold, use, and otherwise process this data following the Data Protection Legislation and as set out in this Policy. The personal information we collect, and use may include, amongst other things:

• Your name;
• Your contact information such as Your email address, postal address, and telephone number or any telephone number used to call us;
• Your demographic information such as age, education, gender, and interests;
• evidence of Your identity (for example passport information);
• the reason for investing;
• unique identifiers such as Your username, account number and password;
• Your payment details and other financial data (for example, Your bank or payment method provider’s name and Your account number and sort code); and
• information about Your visit to our website, including the full Uniform Resource Locators (URL), clickstream to, through, and from our website (including date and time), length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.

In addition to the information you provide, STLAM may have, or may obtain from third parties, information about you, some of which may be personal data. STLAM uses this information to provide its services to you and to help protect you, the STLAM service, and the general public from mistakes, fraud, money laundering, and other problems.

STLAM may also collect information from your mobile phone or other device from which you access the 1Click by STL App, including your IP (Internet Protocol) address, operating system, device identification information, and other information associated with your access to and use of the App. STLAM may also collect information about the websites you have visited before accessing the STLAM service. STLAM may keep and store such information and associate it with your use, to help STLAM identify you and facilitate your use of our service in the future. We may also need additional information from you if you invest a high-value amount or as needed to comply with our anti-money laundering obligations under applicable law.

STLAM may verify and confirm all the information that you provide to us (or that we otherwise collect from your accessing the 1Click by STL App) with third parties. STLAM may also verify such information with identity verification services, electronic databases, social media companies, and credit reporting agencies. From time to time, STLAM may require you to provide us with additional information and/or documentation to confirm your identity and your eligibility to use the STLAM service.

When you access the 1Click by STL app, STLAM may collect and store information regarding your use of the App and the service. This includes information about the frequency with which you access the App, the time you spend there, the way you move through the site, your investment history, and details regarding the amount of money you invest.

If you contact us for any reason, whether by telephone, email, text, or otherwise, STLAM will record and store communications that you have with us for evidence and quality assurance purposes. By contacting us by telephone you agree to our recording of the phone conversation.

Use of Personal Data

STLAM may maintain and use all the information and documentation that you provide, as well as information that we derive from your use of the service, and the information that we obtain about you from third parties, to provide the STLAM service to you, and to enable STLAM to comply with laws and regulations, including those intended to prevent fraud, money laundering, and other abuses of the financial system. STLAM may use your information to contact you as necessary to confirm or complete a transaction, and to allow our agents, partners, and service providers to fulfill their obligations in providing the STLAM service to you. STLAM may also use your information to improve our service, troubleshoot problems, develop new products and services, and create advertising, marketing, and promotional campaigns. We will ask for your consent to send you marketing communications about products and services offered by STLAM. More information about STLAM’s use of your data for marketing and promotion is below. Finally, STLAM may disclose your information to third parties, including government agencies, when STLAM reasonably determines that such disclosure is required by law, such as responses to subpoenas and information requests by law enforcement, financial services regulators, or national security authorities.

STLAM will not sell, rent, or otherwise disclose your information to third-party marketers or others unaffiliated with STLAM for advertising, promoting, or selling other services to you. However, where and to the extent allowed by law, STALM may work with third parties to analyze the information that we gather from you when you visit us online, including our website whether or not you use the STLAM service. STLAM may use the information we gather there, along with the information we obtain from your use of our service, which may include personal data, to advertise and promote STLAM services to you and others. We may customize our marketing and promotional messages to you based on your use of our service, the information that you provide to us or which we otherwise obtain about you, and algorithms designed to help us anticipate your potential needs, based on your information and the information of others who use STLAM services. STLAM believes that such programs provide valuable information and benefits to our current and potential users. However, STLAM will only use your personal data for marketing and promotional purposes if you “opt-in” to such uses, and you can withdraw this permission at any time.

Our Legal bases for using your Personal Information

STLAM only uses your personal information for a specific purpose(s), and before we do so we must have a legal basis. We may use your personal information for each of the following legal bases:

Performance of a contract: This includes providing you with one of our products or services, notifying you of any changes to our services, Apps, our site, or changes to our terms or privacy policy, enabling third parties to perform technical, logistical, or other functions for us, and responding and resolving any complaints you may have.

Consent: You have told us you are happy for us to process your personal information for a specific purpose such as: sending you marketing and promotional communications by email, text, and push notifications, sending you surveys, and engaging with you for the purposes of obtaining your views on our sites, App, or our services, or where otherwise required by law.

For Our Legitimate Interests (to the extent that such interests are not overridden by your interests): This includes: using personal information needed to fulfill our legal and regulatory obligations related to anti-money laundering and counter-terrorist financing; establishing, exercising, protecting, or defending our legal rights and interests; promoting and conducting our business, conducting surveys, satisfaction reports, and market research; developing new products and services, detection, prevention, and prosecution of fraud and theft as well as preventing illicit or prohibited use of our services or other illegal activity; Contacting you to facilitate or progress your use of our Services including any problems you may have in completing your investment, subject always to compliance with applicable law; and managing and operating the financial and commercial affairs of our business. Wherever we use legitimate interest as the ground for processing your personal information you can object to our use of it.

For Compliance with our Legal Obligation: This includes the use of your personal information to comply with legal and regulatory duties related to anti-money laundering, terrorist financing, detection, prevention, and prosecution of fraud and theft, and preventing the illicit use of our services or any other illegal or wrongful activity; comply with Data Protection legislation and any other applicable laws; comply with court orders, disclosures to law enforcement or tax agencies; requests from the Information Commissioner’s Office, the Financial Conduct Authority or other governmental or regulatory agency with supervisory authority over us; and the maintenance of records to comply with legal, audit, regulatory and tax requirements.

Protection of Personal Data collected by STLAM

We have implemented appropriate technical and organizational security measures designed to protect your personal information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of processing, in accordance with applicable law.

Unfortunately, the transmission of information via the internet (including by email) is not completely secure. No method of transmission over the internet, or method of electronic storage, is 100% secure. Although STLAM uses strong methods to protect the data that you provide to us, and we regularly test our information protection practices and technology, STLAM cannot absolutely guarantee its security. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. We will, however, notify you of any breach or other compromise that affects your data, promptly and in compliance with applicable law.

Protecting Your Own Information

It is important to keep your password secure to prevent fraudulent use of your account. Do not disclose your password to anyone else and especially anyone who requests it from you by telephone or email. STLAM will never ask you to provide your password or personal information via email. Please be aware of the following:

• Change your password regularly and avoid using the same password on other websites to prevent hackers from access to your account;
• Avoid simple passwords that can easily be guessed;
• Be aware that public WiFi networks are risky and hackers may capture your online transactions and personal information. Only connect to a network you can trust;
• If you use a shared computer, make sure you log out immediately after you have finished using the website; and
• Beware of ‘phishing’ where criminals may attempt to steal your information by sending you bogus emails.

We take every reasonable step to ensure that your personal information is only retained for as long as it is required for the purposes set out in this Policy. Therefore, 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 or regulatory obligations to which we are subject. This will involve us regularly reviewing our files to check that information is accurate, up-to-date, and still required.

In addition, after you have ceased to be a client, we may take steps to delete your personal information or hold it in a form which no longer identifies you (for example, we may still use your data in an anonymized format for research and other business purposes). The period for which we will retain information about you will vary depending on the type of information and the purposes that we use it for. In general, unless applicable law requires a longer retention period, we will keep our records for as long as you are our client and for a minimum of five and a maximum of ten years after the end of your relationship with us.

Use of Cookies and other Tracking Devices

STLAM uses “cookies” and other tracking devices to help us recognize you, remember your preferences, and facilitate your future investment and other interactions with us. We also use such tracking devices to help us understand consumer behavior on our App, to help us improve it and make it easier for future use. You may be able to disable your device’s use of cookies, but that may slow or prevent your ability to use the STLAM service. For further information please visit cookies.

Your Rights, including the Right to Access and Correct your Personal Data

You have rights that are subject to applicable laws and in accordance with relevant data protection regulations and STLAM’s policies intended to prevent fraud and other abuses of financial services. These rights are;

• the right not to provide your personal information to us (however, please note that we may be unable to provide you with the full benefit of our site, our Mobile App, or our services if you do not provide us with your personal information);
• the right to request access to your personal information, together with information regarding the nature, processing and disclosure of that personal information;
• the right to request the correction of any inaccuracies in your personal information;
• the right to request for the erasure of your personal information. This is also known as the right to be forgotten. We will keep a note of your name if you ask for your personal information to be erased;
• the right that we restrict our use of your personal information;
• the right to object to our use of your personal information. Wherever we use legitimate interest as the ground for processing your personal information you can object to our use of it;
• the right to have certain personal information transferred to another Controller, in a structured, commonly used, and machine-readable format, to the extent applicable;
• where we use your personal information based on your consent, you have the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any processing performed before the date on which we receive notice of such withdrawal, and does not prevent the processing of your personal information in reliance upon any other available legal basis); and
• the right to lodge complaints with a Data Protection Authority regarding the use of your personal information by us or on our behalf.

We may require proof of your identity before we can give effect to these rights. You should also be aware that some of these rights are qualified and not absolute; therefore exemptions or limitations may apply. For example, we can refuse to provide information if fulfilling your request would reveal the personal information about another person, or if you request that we delete information that we are required to retain by law, have compelling legitimate interests to keep, or need access to fulfil our legal obligations.

The quickest and easiest way to make a data subject request is to contact us directly to exercise your rights by emailing cs@stlasstmgt.com. We will endeavor to respond within a reasonable period and in any event within one month (three months for complex or numerous requests), in compliance with Data Protection Legislation. We also reserve the right to charge a reasonable fee (reflecting the costs of providing the information) or to refuse to respond where requests are manifestly unfounded or excessive: in this case, we will explain the situation to you and we will inform you about your rights.

Privacy Policy Changes

STLAM’s privacy policy may change in the future. If that happens, the revised version will be posted on our website, www.stlassetmgt.com, and will be sent to current users via the email addresses associated with their 1Click by STL App registrations.