Privacy Policy

This is the privacy policy of Allocator, the trading name of HedgePo Ltd, a company registered in England with registered number 08319852, and whose registered office is at Stein Richards, 10 London Mews, London, England W2 1HY, on behalf of itself, its group company affiliates and subsidiaries (Allocator).

At Allocator we respect your privacy and are committed to ensuring that your personal information is used in accordance with current data protection legislation. The UK has now left the EU, but continues to meet EU GDPR standards and applies via the UK Data Protection Act 2018 compliance with the EU General Data Protection Regulation ((EU) 2016/679).

This Privacy Policy explains what happens to any Personal Data that you provide to us, is provided to us, or that we collect from you whilst you visit our site, or is processed by Allocator or by 3rd parties on our behalf.

For the purposes of Personal Data processing Allocator identifies the following Data Subject categories:

Investment Manager Contributor (Contributor) – a representative of a company listed on the platform who shares, and updates contact data on behalf of the company;
Investment Manager Individual (Individual) – an individual who is listed on the platform by a Contributor;
Subscribers to Allocator Services, both existing and former (Subscriber);
Suppliers and contractors who provide services to Allocator;
Contacts and interested parties who have responded to marketing campaigns;

You may belong to more than one category.

Information we collect:

In running and maintaining our platform we may collect and process the following data:

Investment Manager Contributor:

When you register an account to become an Allocator user (“User”), we collect information such as your name, phone number, e-mail, company details, country, and a password.
We also collect your IP address, browser type, operating system, mobile carrier, and your ISP, and receive the URLs of sites from which you arrive or leave the Allocator website, or sites that have embedded Allocator platform technology.
We collect information through cookies and other technologies that allow us to recognize you and customize your experience.
As a User you will also be responsible for the other personal data you include in your company profile including the name and job title of any colleagues you include.

Investment Manager individual:

We process your name, job title, e-mail, phone number, company details, country details as well as biography.
The information is provided by the Investment Manager Contributor who is keeping the company account up to date.
Your information is made available only to those Subscribers that your company’s User has granted permission.

Subscribers:

When you register an account to become an Allocator user (“User”), we collect information such as your name, phone number, e-mail, company details, country, and a password.
We also collect your IP address, browser type, operating system, mobile carrier, and your ISP, and receive the URLs of sites from which you arrive or leave the Allocator website, or sites that have embedded Allocator platform technology.
We collect information through cookies and other technologies that allow us to recognize you and customize your experience.

Suppliers and contractors:

We process your name, job title, e-mail, phone number, company details.
The information is provided by Allocator in connection with the services which you provide under contract to Allocator.
Your information is made available only to those persons within the Company Subscribers that your company’s User has granted permission.

Allocator also collects collect and process personal information in the following circumstances:

When you give us your personal information by phone, email, and via our websites, as part of any services we provide. This includes but isn’t limited to information you give us when register with us, request information, work with us, request literature, or signup for newsletters. The information you give us can include your name, address, email address and other contact information. It can also include your financial information and other personal details.
When you visit our website: we automatically collect information which includes: the Internet Protocol (IP) address used to connect your computer to the internet, your login information, your geographic location, your browser and browser plug-in type and version, and your operating system and platform. We also collect information about your visit, including the source of your visit, and the full click path and mouse movement through our sites (including date and time). This includes the services you viewed, searches you made on our sites, page response times, download errors, length of visits to certain pages, page interaction information (such as page scrolling, mouse clicks, mouse movements and keyed text), and how you navigated away from any page and any phone number you use to call our support services.
When we email you: from time to time when you open an email we’ve sent you, we automatically collect information including your geographic location, browser type and version, the device, and the operating system and platform you’re using. We also collect information about your email consumption, including the full click path from within and on to our sites (including date and time), and whether you opened, deleted, forwarded, printed or unsubscribed from the email, and also how long the email was open.
When we receive your information from third parties: We may receive information about you from third parties such as credit reference agencies, payment service providers, or analytics providers.

If we don’t receive all of the personal information we’ve requested from you, then we won’t be able to provide our services for your benefit or use your information for our business purposes.

Use of Your Information:

We process your data relying on the “legitimate interest ground”. Allocator’s legitimate business interest, and purpose of our processing your data, is to provide data and information on the firms and funds in the investment management industry.

Processing your data also allows us to administer your account and customize the service we provide you and other Users as well as to send you service or promotional communications through email and notices on the Allocator web platform.

We do not sell, rent, or otherwise provide personally identifiable information to third parties without your consent except where it is necessary to carry out your instructions (to process your payment information, for example) or as described in this Privacy Policy. Please note that in order to fulfil your requests for paid services, we share your payment information with our payment processor.

When you receive newsletters or promotional emails from Allocator, we will use personalized unique links or similar technologies to determine whether the email has been opened and which links you click. This enables us to provide you with email communications or other information that are more targeted to your needs.

We will rely on our legitimate interests to do this, meaning the provision of electronic direct marketing of our data, services and products, unless legislation requires us to obtain your consent, in which case we will request this from you.

We process and use your personal information in the following ways:

To provide you with any services and/or information you request from us. This also includes carrying out any obligations specified in any contracts between us.
To inform our business decisions, and to deliver a relevant experience.
To comply with our legal and regulatory obligations, co-operate with regulators and law enforcement agencies and to prevent and detect crime.
If we learn of your insolvency or bankruptcy (or any insolvency proceedings), we’ll transfer your details to the Official Receiver or appointed insolvency practitioner(s).
To check instructions you’ve given us or to resolve disputes including to establish, exercise or defend our legal rights.
To improve the quality of our services and to train our staff.
To let you know about any changes we make to our platform and services.
To process any job application you submit, or that an agency submits for you.
To tell you (by mail, email, telephone or otherwise) about products and services we think you could be interested in, based on our products you already have or have shown an interest in. You can opt out of this communication at any time.
To confirm your identity and address, which includes using automated decisions when we carry out financial crime checks.
To request your feedback on a product or service via a third party we’ve chosen (we’ll only share your name and email address).
Gathering data for analysis and research, and to provide management information or other services internally and to third parties.
To administer our sites and for internal operations, including troubleshooting, data analysis, load management, testing, research, statistical and survey purposes.
To improve our sites to make sure that our content is as effective as we can for you and for the service we provide.
So you can choose to participate in any interactive features of our platform or sites.
As part of our efforts to keep our sites safe and secure and to prevent and detect money laundering, financial crime and other crime.
To monitor, record, store and use any telephone, email or other communication with you. We’ll update your records with any new information you or a third party give us, and we’ll add it to any information we already have.
When you call us or contact us we’ll collect the information and may keep a copy of the call or email for our records and for security purposes. We’ll also use your information to help improve our efficiency and effectiveness.
To deal with any enquiries or issues you have about how we collect, store and use your information, or any requests made by you for a copy of the information we hold about you.
For internal corporate reporting, business administration, ensuring adequate insurance coverage for our business, ensuring the security of company facilities, research and development, and to identify and implement business efficiencies.

Information Security:

We take the security of your personal data very seriously, and we use appropriate technologies and procedures to protect your personal information.

We keep our data security procedures up to widely accepted international standards and only work with recognised suppliers. In addition, we review our policies regularly and update them whenever needed to protect you, and to meet our business needs, changes in technology, and regulatory requirements.

Here are examples of the ways we protect your data:

We have appropriate technical and organisational measures in place to protect you against accidental loss and unauthorised access, use, destruction or disclosure of your data.
We have a business continuity and disaster recovery plan that is designed to help us offer our services and protect our people and assets no matter what happens.
We place appropriate restrictions on access to personal information.
We implement measures and controls, including monitoring and physical measures, to store and transfer data securely.
We complete data protection impact assessments in accordance with legal requirements and our business policies.
We provide data security training for our employees.
We use a stringent approach to vendor risk management.

The internet is an open medium and we can’t guarantee that any information you send to us by email or via our platform won’t be intercepted or tampered with. Any transmission is at your own risk. Once we’ve received your information, we use strict procedures and security features to try to prevent unauthorised access.

Marketing:

We may collect and use your personal information for undertaking marketing by email, telephone and post.

We may send you certain direct marketing communications (including electronic marketing communications to existing customers) if it is in our legitimate interests to do so for marketing and business development purposes.

However, we will always obtain your consent to direct marketing communications where we are required to do so by law.

You have the right to ask us not to process your personal information for marketing purposes. You can do this by contacting us by post or email using the details in the contact section below. You can also unsubscribe from emails by following the unsubscribe instructions included in every email. Please note: requests to unsubscribe via post, email or secure message are processed internally and may take longer to mark you as unsubscribed than using the unsubscribe link in the footer of our emails.

How long do we retain your data?

Contact details of Investment Manager Contributors, Individuals and Subscribers are stored for varying lengths depending on the nature and purpose for which it was collected. Allocator will review your personal data periodically to ensure it is still necessary to be retained for the purpose for which it was collected.

Page View data meaning statistics as to which firm has accessed your firm profile on our web product and how often is kept for the lifetime of the product so that we can understand changes to usage patterns over time.

Billing data is kept for the lifetime of our contract with you and then ongoing for seven years to comply with tax legislation.

Backups of our products are retained for a year. However, we have processes to ensure if a restore is required Subject Rights are maintained.

Financial data is retained is accordance with statutory and regulatory requirements.

Marketing and sales data is retained and limited in accordance with this policy.

Use of Cookies:

Cookies provide information regarding the computer used by a visitor. We may use cookies where appropriate to gather information about your computer in order to assist us in improving our website. We may gather information about your general internet use by using the cookie. Where used, these cookies are downloaded to your computer and stored on the computer’s hard drive. Such information will not identify you personally. It is statistical data. This statistical data does not identify any personal details whatsoever. You can adjust the settings on your computer to decline any cookies if you wish. This can easily be done by activating the reject cookies setting on your computer.

Logs of access recorded by IP address are used in the process of potential system abuse and crime detection. This access is anonymized unless it is related to a sign-in by a Subscriber userID.

Logs of page views and interaction with our web product are maintained to help us to provide you with a more personalized user experience in relation to the provision of services to you.

Transfers outside the EEA:

We partner with companies who provide PaaS, CRM services, web servers, data centers and other services, who have access to contact data that we hold. Appropriate data protection is provided by a Model Clauses schedule in the relevant contracts.

Subscribers are globally distributed and have access to visible contact data in our products. Where Subscribers operate outside of a territory that is deemed to have “Adequate” status by the European Commission or are not certified to US/EU Privacy Shield, appropriate data protection is provided by a Model Clauses schedule in the Terms and Conditions of service.

A definition of Adequate status and a list of relevant countries can be found here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en

Model clauses permit such transfer under Article 46 of the General Data Protection Regulation (the “GDPR”). You can find a link to the model clauses here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en

Disclosing Your Information:

We will not disclose your personal information to any other party other than in accordance with this Privacy Policy and in the circumstances detailed below:

In the provision of our services and information about our services.
In the event that we sell any or all of our business to the buyer.
Where we are legally required by law to disclose your personal information.
To further fraud protection and reduce the risk of fraud.

Third Party Links:

On occasion we include links to third parties on this website. Where we provide a link it does not mean that we endorse or approve that site’s policy towards visitor privacy. You should review their privacy policy before sending them any personal data.

What are your rights in relation to our use of your information?

You have rights under data protection law in relation to our use of your information, including to:

request access to your information, which you can do by emailing dp@allocator.com stating you are submitting a Subject Access Request
update or amend your information if it is inaccurate or incomplete by emailing dp@allocator.com requesting an update
object to certain uses of your personal data (which includes direct marketing and processing based on legitimate interests and processing for purposes of scientific or historical research and statistics) on grounds relating to your particular situation by emailing dp@allocator.com
request the deletion of your information, or restrict its use, in certain circumstances (for example you can request that we erase your information where the information is no longer necessary for the purpose for which it was collected, unless certain exceptions apply) by emailing dp@allocator.com;
withdraw any consents you have provided in respect of our use of your information either by clicking unsubscribe links in emails or emailing dp@allocator.com;
request the return of information you have provided to us, to use for your own purposes (often called your right to data portability) where the processing is based on your consent or for the performance of a contract, and the processing is carried out by automated means;
lodge a complaint with the Information Commissioner’s Office (https://www.ico.org.uk/global/contact-us/email/) [or other relevant supervisory authority].

We may need to ask you for further information and identification to help us to comply with this request. More information about these rights can be found at https://ico.org.uk/for-the-public/. If you have any questions about these rights, or you would like to exercise any of them, please contact us at dp@allocator.com

Contacting Us:

Please do not hesitate to contact us regarding any matter relating to this Privacy Policy at dp @allocator.com

Changes to this policy:

We keep this privacy policy under regular review and we will place any updates on this webpage. We will update or amend this policy from time to time, to comply with law or to meet our changing business requirements. You should bookmark and periodically review this page to make sure that you are familiar with the most current version and so you’re aware of the information we collect, how we use it and under what circumstances we disclose it. We will inform you of any material changes to the privacy notice. This privacy notice was last updated on 11 June 2024.