Privacy policy.

Privacy Policy

This policy covers Middleton Advisors Ltd’s (‘we’, ‘us’ ‘our’) use of personal information that we collect when you use  www.middletonadvisors.com.

We ask that you read this privacy policy carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information, and on how to contact us and supervisory authorities in the event you have a complaint.

Our nominated representative for the purposes of this is Tom Hudson, Director, Middleton Advisors Ltd.

Who we are

We are Middleton Advisors Limited. Our registered office is: 67C Innovation Drive, Milton Park, Abingdon, Oxon OX14 4RQ.

Middleton Advisors Ltd collects, uses and is responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.

The personal information we collect and use. Information collected by us

In the course of us providing services to you, we may collect the personal information that you provide. This information may consist of:

• Name, business/residential address, phone number, email address.
• IP addresses and cookies.

Who we share your personal information with

We only share your personal information with reputable third-parties to help us provide our services to you and who take the security of your data seriously. Some of those third-party recipients may be based outside the European Economic Area. For further information including on how we safeguard your personal data when this occurs, see below ‘Transfer of your information out of the EEA’.

We will share personal information with law enforcement or other authorities if required by applicable law.

How long your personal information will be kept

We will hold your personal information for no longer than necessary (unless we are required to hold it for longer to comply with a legal requirement or for our legitimate business purposes).

Reasons we can collect and disclosure of your personal information. Uses made of the information

We use information held about you in the following ways.

Information you give to us. We will use this information:

• to help us provide our services to you
• to notify you about changes to our services; and
• to ensure that content from our site is presented in the most effective manner for you and for your computer.

Information we collect about you. We will use this information:

• to administer our site, for internal operations, including troubleshooting, data analysis, testing, research and for statistical and survey purposes
• to improve our site to ensure that content is presented in the most effective manner for you and for your computer
• as part of our efforts to keep our site safe and secure.

Information we receive from other sources. We may combine this information with information you give to us and information we collect about you, and may us this information and the combined information for the purposes set out above.

Disclosure of your information

We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

We may also share your information with selected third parties including:

• buyers and sellers of property, surveyors, sub-contractors and business associates for the conclusion and performance of contracts we enter into with them or you
• Those whose details you supply to us.

In addition, we may disclose your personal information to third parties:

• in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets
• if Middleton Advisors Corporate Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; and
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Use [LINK], any contract you enter into with us and other agreements; or to protect the rights, property, or safety of Middleton Advisors Corporate Ltd, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
• In order for us to comply with HMRC Regulations (Know Your Client / Anti-Money Laundering) we can use a company called Callcredit to validate the information we are given. For more information:

https://www.callcredit.co.uk/legal-information/bureau-privacy-notice

Where we store your personal data

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for third parties with whom we work. Such staff may be engaged in, among other things, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Your rights

Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:

• access your personal information and certain other supplementary information that this Privacy Notice is already designed to address
• require us to correct any mistakes in your information which we hold
• require the erasure of personal information concerning you in certain situations
• receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third-party in certain situations
• object at any time to processing of personal information concerning you for direct marketing
• object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
• object in certain other situations to our continued processing of your personal information
• otherwise restrict our processing of your personal information in certain circumstances.

 For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

 If you would like to exercise any of those rights, please:

• email, call or write to us (see ‘How to contact us’ below)
• let us have enough information to identify you e.g. name and work email address
• let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
• let us know the information to which your request relates.

Your privacy is of the utmost importance to us and we will never release your details to third-party organisations for the purpose of marketing or communications without your prior agreement.

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide users with a better experience when they browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them please see our Cookie Policy.

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

We use the latest Secure Server Technology to ensure that all data submitted through our website is protected to the highest standards.

Other Sites

Our site may, from time to time, contain links to and from the websites of certain partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these have their own privacy policies and that we do not accept any responsibility or liability for those policies. Please check these policies before you submit any personal data to these websites.

How to complain

We hope that we can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred.

The supervisory authority in the UK is the Information Commissioner who may be contacted on telephone: 0303 123 1113.

 Changes to this privacy notice

This privacy policy was last updated on 24 May 2018.

We may change this privacy policy from time to time. You should check this policy occasionally to ensure you are aware of the most recent version.

How to contact us

Please contact us if you have any questions about this privacy notice or the information we hold about you.

If you wish to contact us, please send an email to admin@middletonadvisors.com or contact us at:

Middleton Advisors Ltd
67C Innovation Drive
Milton Park
Abingdon
Oxon OX14 4RQ

Tel: 01235 436275