Effective date: September 13, 2022
FirstPoint Equity Capital Ltd (“us”, “we”, or “our”) operates the https://www.firstpointequity.com website and the FirstPoint mobile application (hereinafter referred to as the “website”).
This page provides information about how we gather, use and disclose personal data when you use our website and the choices you have associated with that data.
We use your data to provide and improve the website. By using the website, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.
DEFINITIONS
Website: Website means the https://www.firstpointequity.com website and the FirstPoint mobile application operated by FirstPoint Equity Capital Ltd.
Personal Data: Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
Usage Data: Usage Data is data collected automatically either generated by the use of the website or from the website infrastructure itself (for example, the duration of a page visit).
Cookies: Cookies are small files stored on your device (computer or mobile device).
Data Controller: Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.
For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.
Data Processors (or website providers): Data Processor (or website provider) means any natural or legal person who processes the data on behalf of the Data Controller.
We may use the services of various website providers in order to process your data more effectively.
Data Subject (or User): Data Subject is any living individual who is using our website and is the subject of Personal Data.
Information Collection and Use
We collect several different types of information for various purposes to provide and improve our service to you.
TYPES OF DATA COLLECTED
Personal Data
While using our website, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:
First name and last name
Phone number
Address (including email address)
Cookies and Usage Data
Usage Data
We may also collect information that your browser sends whenever you visit our website or when you access the website by or through a mobile device (“usage data”).
This usage data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When you access the website with a mobile device, this usage data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
Tracking & Cookies
We use cookies and similar tracking technologies to track the activity on our website and we hold certain information.
Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our website.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our site.
Examples of Cookies we use:
Session Cookies. We use Session Cookies to operate our website.
Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
Security Cookies. We use Security Cookies for security purposes.
Cookies we use:
| wp-settings-time- | WordPress | WordPress also sets a few wp-settings-{time}-[UID] cookies. The number on the end is your individual user ID from the users database table. This is used to customize your view of admin interface, and possibly also the main site interface. |
| wp-setting- | WordPress | WordPress also sets a few wp-settings-[UID] cookies. The number on the end is your individual user ID from the users database table. This is used to customize your view of admin interface, and possibly also the main site interface. |
| wordpress_test_cookie | WordPress | WordPress sets this cookie when you navigate to the login page. The cookie is used to check whether your web browser is set to allow, or reject cookies. |
| wordpress_sec | WordPress | Essential WordPress session management cookies for logged in users. |
| wordpress_logged_in | WordPress | After login, wordpress sets the wordpress_logged_in_[hash] cookie, which indicates when you’re logged in, and who you are, for most interface use. |
| gdpr_popup | FirstPoint Equity | Used to detect if GDPR popup has been shown previously |
| _ga | Google Analytics | Used to determine a user’s inclusion in an experiment and the expiry of experiments a user has been included in. |
| _gid | Google Analytics | Used to distinguish users. |
| _gat_UA-********-1 | Google Analytics | This is a pattern type cookie set by Google Analytics, where the pattern element on the name contains the unique identity number of the account or website it relates to. It appears to be a variation of the _gat cookie which is used to limit the amount of data recorded by Google on high traffic volume websites. |
Use of Data
The information we collect and what we use it for will depend on the nature of our business relationship with you. FirstPoint Equity Capital Ltd uses the collected data for various purposes:
To provide and maintain our website
To notify you about changes to our website
To allow you to participate in interactive features of our website when you choose to do so
To provide customer support and maintain our business relationship with you
To gather analysis or valuable information so that we can improve our website
To monitor the usage of our website
To detect, prevent and address technical issues
Legal Basis for Processing Personal Data
FirstPoint Equity Capital Ltd legal basis for collecting and using the personal information described in this Privacy Policy depends on the personal data we collect and the specific context in which we collect it.
FirstPoint Equity Capital Ltd may process your personal data because:
We need to perform a contract with you
You have given us permission to do so
The processing is in our legitimate interests and it is not overridden by your rights
To comply with the law, including regulatory requirements and guidance
Retention of Data
FirstPoint Equity Capital Ltd will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.
FirstPoint Equity Capital Ltd will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our website, or we are legally obligated to retain this data for longer periods.
Transfer of Data
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
If you are located outside United Kingdom and choose to provide information to us, please note that we transfer the data, including Personal Data, to United Kingdom and process it there.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
FirstPoint Equity Capital Ltd will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.
DISCLOSURE OF DATA
Disclosure for Legal Compliance
Under certain circumstances, FirstPoint Equity Capital Ltd may be required to disclose your personal data if required to do so by law or in response to valid requests by the Information Commissioner or public authorities (e.g. a court or a government agency).
Legal Requirements
FirstPoint Equity Capital Ltd may disclose your Personal Data in the good faith belief that such action is necessary to:
To comply with a legal obligation
To protect and defend the rights or property of FirstPoint Equity Capital Ltd
To prevent or investigate possible wrongdoing in connection with the website
To protect the personal safety of users of the website or the public
To protect against legal liability
Security of Data
The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. Whilst we have put in place measures to minimise cyber risk we are not liable to users of this website for any cyber events and we encourage users of this website to maintain their own appropriate cyber security arrangements.
Your Data Protection Rights
FirstPoint Equity Capital Ltd aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.
If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us. We will respond without delay and within one month of the request. If the request is complex, or if you make a number of requests, then we may extend the time limit by up to a further two months.
In certain circumstances, you have the following data protection rights:
The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
The right to object. You have the right to object to our processing of your Personal Data.
The right of restriction. You have the right to request that we restrict the processing of your personal information.
The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
The right to withdraw consent. You also have the right to withdraw your consent at any time where FirstPoint Equity Capital Ltd relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests. This is another security measure to ensure that personal information is not disclosed to any person who has no right to receive it. The timescale for responding to your request does not begin until you provide this information.
Fees
You will not have to pay a fee to access your personal information. In some cases, we may charge a reasonable fee for administrative costs if your request is unfounded or excessive, or if you request multiple copies of the information.
Complaints
Complaints should be addressed in the first instance to info@firstpointequity.com Should that not prove satisfactory then you have a right to contact the Information Commissioner in respect of our handling and use of your personal data.
Service Providers
We may employ third party companies and individuals to facilitate our website (“Service Providers”), provide the website on our behalf, perform web-related services or assist us in analysing how our website is used.
These third parties have access to your personal data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Links to Other Sites
Our website may contain links to other sites that are not operated by us. These links are provided only as a convenience. If you click a third-party link, you will be directed to that third-party’s site. The inclusion of any link is not and does not imply an affiliation, sponsorship, endorsement, approval, investigation, verification, or monitoring by FirstPoint Equity of any information contained in any third-party website. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility or liability to you whatsoever for the content, privacy policies or practices of any third-party sites or services.
Children’s Privacy
Our website does not address anyone under the age of 18 (“children”).
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us. If we become aware that we have collected personal data from children without verification of parental consent, we take steps to remove that information from our servers.
Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
We will let you know via email and/or a prominent notice on our website, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
Contact Us
If you have any questions about this Privacy Policy, please contact us:
By email: info@firstpointequity.com