1. About us
This website, www.uk-edge.centaur.jpmorgan.com (the website) is owned by Centaur Communications Limited, a company registered in England and Wales under company number 01595235 (Centaur, we, us, our).
The website has been created in partnership with J.P. Morgan Asset Management (UK) Ltd, a company registered in England and Wales under company number 01161446 (J.P. Morgan Asset Management).
We are each committed to protecting your personal data and have agreed with each other that we will cooperate to ensure that your personal data is processed in accordance with data protection laws and so that your rights can be exercised effectively.
2. What personal data do we collect?
“Personal data” means information which identifies you as well as any information relating to you.
For the most part we receive your personal data directly from you, for example, when you register as a member of THE UK EDGE, complete your member profile, submit posts or other user generated content to the website or when you contact us.
When you set up an account with us you will be asked to provide:
- your email address;
- your full name;
- your job title and the company you work for;
- which financial topics are of interest to you;
- where you are based; and
- your password.
You must provide this information as a minimum in order to register as a member.
Immediately upon registration, a publically available profile will automatically be generated on the website which will include details of your full name, your job role and the company you work for.
You have the option of editing your profile to add further information. This includes:
- a profile picture
- a tag-line about yourself and further bio/expertise;
- a website for you or the company you work for;
- your email address and phone number;
- links to your social media accounts (such as Twitter, Facebook, LinkedIn and Google Plus);
- where you are from and your areas of interest; and
- content you feature in or you’ve contributed to.
If you choose to include this information in your profile, please note that it will be publically available via the website. You can edit the information in your profile at any time via your account settings and you also have the option to permanently delete your account, including any content you have created.
Your profile also contains publically available information about other members you are following on the website and the members who are following you.
User generated content:
The website allows our members to post user generated content such as comments on an article or asking a question to the membership community.
From time to time other users may post articles, videos or comments which feature you. If you have any concerns about content posted by other users which features your personal data, please contact us email@example.com.
Information collected from other sources:
As well as information we receive directly from you, we also occasionally process information about you which we receive from other sources.
Other members: We may have initially received your email address from one of our other members to invite you to join the website, if they have made use of the ‘invite someone’ feature.
Third party applications: If you access the website through a third-party connection or log-in, for example, through LinkedIn, by linking your account to the website, that third party may pass certain information about your use of its service to us. This information could include, but is not limited to, the user ID associated with your account, any information that you have permitted the third party to share with us, and any information you have made public in connection with that service. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to us. You may also unlink your third party account from the website by adjusting your settings on the third party service.
Device and browsing data: In addition, we may automatically collect information about any website that you came from or are going to. We also collect information about the pages of the websites which you visit, the links you click on, IP addresses, the type of browser you use and the times you access the websites. Some of this information is aggregated and is not used to identify you, but we also use analytics software on the websites which allows us to link information about your use of the websites back to you, where you have logged into your account. We may observe your use of the websites and whether you open emails we have sent to you. We may infer and derive certain information from these observations such as what additional brands, subscriptions, events or services you or a user similar to you may be interested in. This information will be used for our own internal and marketing purposes.
Publically available sources: We (and our marketing service providers) also use publically available sources and business contact lists sourced from third party data providers to research prospective customers in order to contact them for marketing purposes regarding products and services relevant to them .
3. How will your personal data be used?
In accordance with data protection laws, we will only process your personal data where we have a lawful basis for doing so. These bases are: (i) where it is necessary for the performance of a contract we have with you; (ii) where you have provided your consent; (iii) where it is necessary for us to comply with a legal obligation that we are under; or (iv) where it is in our (or a third party’s) legitimate interests and such interests do not prejudice your rights or freedoms.
- administer the website, for example, access controls, and provide customer services (legitimate interests, of us and our customers to ensure a good quality of service and security);
- aggregate information about you with other users (legitimate interests, of us, to better understand what services our users will be interested in);
- gather information to form statistical and trend analysis including to monitor user demographic (legitimate interests, of us, so we can better understand those that use our products and services and improve our products, services and marketing practices);
- communicate with you, including responding to your enquiries (legitimate interests, of us, to run the website, or consent);
- investigate any complaints about the website (legitimate interests, for us and our customers, to ensure that we maintain high service levels);
- display your profile on our website (legitimate interests, of each of us, to create a community of business professionals, and in respect of the optional information you post on your profile, consent);
- send you newsletters and notifications about content and conversations you have contributed to (legitimate interests, each of us, so you are up to date with our content); and
- contact you for business- to-business marketing purposes including about The UK Edge and other products and services of each of Centaur and J.P Morgan Asset Management which we think may be of interest to you (legitimate interests, of us to promote our products and services and of our customers and prospective customers, to keep them up to date with promotions, events and subscriptions which may be relevant to their professions and job roles).
4. Who do we share your personal data with?
J.P. Morgan Asset Management : In the course of providing the website to you, we may need to share information with J.P. Morgan Asset Management and they may need to share information with us, for example, if one of us receives a request from you and we need the other party’s input to respond to you. We also will let J.P.Morgan Asset Management know if you indicate to us that you would like to receive information from them about their goods and services.
Group companies: We may share your personal data with our affiliate companies and their brands for the above purposes (legitimate interests, of us, for internal efficiencies). For a list of Centaur’s brands, please see www.centaurmedia.com/brands).
Service providers: We employ the services of third party service providers to help us in certain areas, such as website and platform hosting, management and maintenance and marketing and analytics. In some cases these third parties may receive your personal data (legitimate interests, of us, for service efficiency and to benefit from third party expertise, and of our customers, so they experience a good quality of service). However, at all times, we will control and be responsible for the use of your personal data and we will endeavour to ensure that our service providers are bound by contractual obligations to only process your personal data in accordance with our instructions.
Aggregate information: As mentioned above, we may use aggregated information so we can administer and improve the website, analyse trends and gather broad demographic information and detect suspicious or fraudulent transactions. We may pass this information to third parties. In most cases this information will be anonymised, meaning that you will not be able to be identified from it.
Administration of justice: We may occasionally be required by law, court order or governmental authority to disclose certain types of personal data (necessary to comply with a legal obligation, or for legitimate interests in connection with a legal claim against us). Examples of the type of situation where this would occur would be:
- in the administration of justice; or
- where we have to defend ourselves legally.
Sale of the business: In the event that our business is sold or integrated with another business, your details may be disclosed to our advisers and any prospective purchaser’s advisers and passed to the new owners of the business (legitimate interests).
5. Newsletters, marketing communications and other notifications
By registering as a member you will automatically be opted-in to receive our newsletters by email which contains a round up of content from Centaur’s Money Marketing brand and from J.P.Morgan Asset Management.
You will also be opted-in to receive other notifications by email such as if someone engages with content you have posted, or in relation to conversations on the website which you have participated in or when another user wants to connect with you.
If at any time you no longer want to receive these communications you can adjust your notification preferences in your account.
In addition to communications relating to the UK Edge, you may also from time to time receive other marketing communications from us (by email) or, separately, from J.P. Morgan Asset Management about each of our respective products and services.
You have a right to ask each of us not to use your personal data for direct marketing purposes at any time and you can unsubscribe to marketing emails each of us send you by clicking on the unsubscribe link at the bottom of those emails.
Please note that even if you choose to opt-out from our newsletter or marketing lists you may still receive other important information from us, for example, responses to communications you send to us or other essential communications for the management of your account (such as password reset emails).
Our site contains links to other websites. Some of the links may be to sites which are independently run by either of us (and so will be subject to our different and independent privacy policies which will be displayed on those sites). Where the links are to third party websites, note that we are not responsible for the privacy policies or practices of those other websites. We encourage you to review the privacy policies of those other websites so you can understand how they collect, use and share your personal data.
We have implemented reasonable technical and organisational measures designed to secure your personal data from accidental loss and from unauthorised access, use, alteration or disclosure. However, the Internet is an open system and we cannot guarantee that unauthorised third parties will never be able to defeat those measures or use your personal information for improper purposes.
8. Do we make your personal data available outside the EEA?
We may transfer some of your personal information to the United States of America, to Singapore and to Australia as we have affiliates in these jurisdictions. In addition, we and service providers processing personal data on our behalf, transfer personal data to servers outside the EEA including in the Untied States of America and India for storage purposes. These countries may not have equivalent data protection legislation to the UK. However, when we transfer your personal information in this way we will endeavour to ensure that adequate measures are in place to keep your personal data secure, including via standard contractual clauses and Privacy Shield.
Please note we do not restrict access to the website by territory, so people browsing the website from around the world may view any personal data you include on your publically available profile.
9. Your rights
Under certain circumstances, by law, you have the following rights in relation to your personal data:
- a right of access to your personal data held by us;
- a right to receive certain personal data in an accessible, machine-readable format;
- a right to object to processing of your personal data where we are relying on legitimate interests (or those of a third party) for a particular purpose and you believe your circumstances mean you are unjustifiably prejudiced by this processing and where we do not have compelling legitimate interests to override such objection;
- a right to ask us not to process your personal data for direct marketing purposes (including profiling for the purpose of direct marketing);
- where we have sought your consent to use your personal data for a particular purpose, a right to withdraw your consent at any time;
- a right to have inaccurate personal data rectified;
- a right to have certain personal data erased where it is no longer necessary for us to process it, where you have withdrawn your consent, where you have objected to our processing as set out above, where your personal data has been unlawfully processed, or where erasing your personal data is required in accordance with a legal obligation;
- a right to request the restriction of processing of your personal data which enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it; and
- a right to complain to your data protection supervisory authority.
In order to protect you, we reserve the right to verify your identity before processing any such request.
If you want to exercise your rights you should direct your request to Centaur at firstname.lastname@example.org. Centaur will liaise with J.P.Morgan Asset Management as necessary in order to respond to your request.
If you are unsure about your rights you should contact your data protection supervisory authority. In the UK this will be the Information Commissioner’s Office.
If you contact us in relation to your rights we will do our best to accommodate your request or objection. Please note, however, that not all rights are absolute.
10. Updating your personal data
You may review, correct, update or change your personal data at any time by editing your profile and account details via your online account.
11. How long do we keep your personal data?
13. Our Relationship with J.P. Morgan Asset Management
Us and J.P.Morgan Asset Management have different roles in respect of the website and our users.
Centaur is responsible for operating the website, providing customer services, promoting the website and sending marketing communications about The UK Edge website.
Each of us posts content on the website and each of our personnel may respond to comments and questions you post on the website.
J.P.Morgan Asset Management is responsible for any communications it or its personnel provide to you via the UK Edge website (or by any other means) and Centaur is responsible for any communications it or its personnel provide to you via the UK Edge website (or by any other means).
J.P.Morgan Asset Management process personal data they hold about you, in accordance with their own, independent, privacy practices and policies. To find out more about how J.P.Morgan Asset Management processes your personal data please refer to their privacy notice which can be found here.
If you receive marketing from J.P.Morgan Asset Management and you would like to contact J.P.Morgan Asset Management about that or exercise your right to object to them processing your personal data for direct marketing purposes you should contact them at email@example.com.
14. How to contact us
As a reminder, if you have any questions about this statement or your personal data, please contact us at firstname.lastname@example.org. Centaur will liaise with J.P.Morgan Asset Management as necessary in order to respond to your enquiry.