The Underlying Principle

Fundhouse Limited and Fundhouse Bespoke Limited (“Fundhouse”, “we”, “us” or “our”) are committed to protecting the privacy of individuals whose data it processes (“you” or “your”). Fundhouse and its directors, officers and employees hereafter referred to as “Fundhouse” respect your privacy and the confidentiality of your personal information. Fundhouse may from time to time update this policy.

Who we are

Fundhouse is a provider of fund research, asset allocation and model portfolios. A times we do collect personal data and we are committed to upholding high standards protecting that data – whether as a controller of the data or as a processor of it.
Within this document, we aim to give you sufficient information to assess how we collect and process your personal data.

Are you concerned?

Please contact Fundhouse at 7 Chapter House, 33 London Road, Reigate RH2 9HZ if you have any queries in relation to the processing of your personal data under this policy and we will get back to you. The Managing Director, Rory Maguire, is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact Fundhouse.

Categories of data and how we may receive it

  • Visitors and users of the website (you may be a user of our website or have signed up to newsletters)
  • Clients and prospects
  • Service providers to Fundhouse
  • Employees and job applicants
  • General business contacts

Each is discussed separately further on. As a “data subject”, you have very important legal rights and you can, for example, do the following:

  • Request and have access to the data we hold;
  • Have us change it, if there are any errors;
  • Ask us to stop processing it (you can object), assuming we have no legal obligation to do so;
  • Request that we delete your personal information if there is no valid reason to continue holding it;
  • Object to us processing your personal data
  • Understand the restrictions around the processing of your personal data and to restrict it further;
  • Request we send your data to a third party you authorise;
  • Withdraw your consent for us to hold and process your personal data. If you would like to exercise any of these rights, please contact Fundhouse.
  • You should not incur a fee for requesting your data, assuming your request is not overly repetitive.
  • We are registered with the Information Commissioners Office (ICO) and you can complain directly to them (see here www.ico.org.uk). However, we would appreciate the chance to deal with your concern directly, if at all possible.

GDPR

You may have seen the acronym before. Within this document, we aim to outline your data protection rights under the EU data protection regime introduced by the General Data Protection Regulation (Regulation 2016/679) (the “GDPR”).

Disclosures of your personal data

We will not disclose personal information to any third parties, unless:

  • We may sell the business in whole or in part and the buyer may need access to information in order to perform a detailed due diligence on us. This would extend to their agents, such as their auditors or corporate finance partners;
  • Where new clients may ask us for details about existing clients;
  • Our suppliers may have access to this information (such as our IT suppliers);
  • Any providers of references or other checks like criminal checks;
  • We are required by law to do so.

Where we hold personal data, we will manage the security around it, such as ensuring there is limited access to it and it is encrypted.

Visitors and Users of our Website (www.fundhouse.co.uk)

During a user’s registration and use of this website, Fundhouse may collect “personal information” such as an individual’s name, company name, telephone number, email address, FCA Number, and role. Fundhouse collects, stores and processes this information in its capacity as a data controller and processor, and does so on the basis of legitimate interest. Personal information that you supply to us via this website is only used and processed for the purpose for which we request the information as stated in the relevant web pages, and/or to the extent necessary to enable Fundhouse to meet its obligations to you and to comply with our legal obligations, and occasionally to inform you of new services or products offered by Fundhouse. Personal information will be held for as long as is necessary to provide account access and until a user terminates their account. Importantly, this website is designed for adults only and is not intended for children and we do not knowingly collect data relating to children.

Fundhouse will not disclose your personal information to third parties unless:

  • Fundhouse is permitted or required to do so by law; or
  • It is in the public interest to do so; or
  • It is necessary to protect the rights of its directors, employees or staff; or
  • You have expressly authorised Fundhouse to do so.

Fundhouse may from time to time use your personal information to compile profiles for statistical purposes. However, such profiles or statistical data cannot be linked to any identifiable individual. Fundhouse has put controls in place to prevent unauthorised access to, modification or destruction of your personal information, whether accidental or deliberate. These controls are based on the requirements of the business and conform to commonly accepted industry standards as well as contractual and legal requirements.

Fundhouse reserves the right to amend this online privacy policy at any time by posting the amended policy on our website. Unless otherwise stated, the current version will apply each time you access our website.

You can contact us at any time to:

  • Request access to information that Fundhouse has about you.
  • Correct any information that Fundhouse has about you.
  • Delete information that Fundhouse has about you.
  • Unsubscribe from all communications.

Use of Forms Online: As some further background, we tend to forms online, which at times includes personal data you provide if you subscribe to our content. What sorts of data could this be? It may be your name, date of birth, address, email address, telephone numbers, job title, any IP address, your log in names and the browser you use. Very importantly we do not collect any sensitive personal data. For example, we will not collect data on your ethnicity, religion, gender, sexual orientation, criminal convictions, politics or your health. We will use your personal data in the following circumstances: where it is necessary for our legitimate interests, or those of a third party (including in relation to the sending of electronic marketing communications) and where your interests and fundamental rights are not overridden by those interests, or where we need to comply with a legal or regulatory obligation. Your personal data may be processed by Fundhouse or its sub-processors (or any of their affiliates, agents, employees, delegates or sub-contractors) for the following purposes:

Marketing communications: We may also send you marketing information, such as any services we may offer, newsletters or events that may be occurring. Importantly, we will only do this when we believe you have a) subscribed to Fundhouse and b) there is likely a legitimate reason to send you information. You can also unsubscribe at any time.

Securing the data: Where we hold personal data, we will manage the security around it, such as ensuring there is limited access to it and it is encrypted.

How long we hold data: All personal data will only be retained for as long as necessary to fulfil the requirements we have or to satisfy other needs, such as legal, regulatory or reporting needs.

Other links: Should you use a link on our website that directs you to a non-Fundhouse website, we are not responsible for the privacy and security of that website.

Clients and Prospects of Fundhouse

We may store the following personal information about you: your name, title, address, contact numbers, date of birth and other information that is important under the know your client rules, such as copies of your identification (like passports, ID documents), utility bills, bank details and your national insurance details. This detail may be gathered in different ways and by different people at Fundhouse. For example, we may gather information on email, on the phone or even online. Sometimes your information may be sent to us by third parties. How could we use your data?

  • We may email you or call you;
  • We may send you a marketing message. As before, these need to be for legitimate reasons;
  • We may have some legal obligation;
  • We may also need to fulfil our anti money laundering assessments (and any extensions of this, such as concerns around fraud, theft, tax evasion, corruption and terrorism);
  • We may be asked by prospects to reference a client that we provide similar services to;

We will not expressly ask your consent to process your personal data (on the basis laid out above), but you can unsubscribe at any time.

Securing the data: Where we hold personal data, we will manage the security around it, such as ensuring there is limited access to it and it is encrypted.

How long we hold data: All personal data will only be retained for as long as necessary to fulfil the requirements we have or to satisfy other needs, such as legal, regulatory or reporting needs.

Cookies: Cookies are little files that help firms like Fundhouse understand your activities online. It analyses various aspects like website traffic and your website history. By knowing this information, in theory we can direct more personal information to you. We only use cookies when users log in to our website, otherwise we do not use cookies. If you are uncomfortable with this, please refuse all cookies.

Service Providers to Fundhouse

We may store the following personal information about you: your name, title, address and contact numbers. This detail may be gathered in different ways and by different people at Fundhouse. For example, we may gather information on email, on the phone or even online. Sometimes your information may be sent to us by third parties.

How could we use your data?

  • We may email you or call you;
  • We may have some legal obligation;
  • We may also need to fulfil our anti money laundering assessments (and any extensions of this, such as concerns around fraud, theft, tax evasion, corruption and terrorism);
  • We may be asked by prospects to reference a supplier as part of their due diligence on us;

We will not expressly ask your consent to process your personal data (on the basis laid out above), but you can unsubscribe at any time.

Securing the data: Where we hold personal data, we will manage the security around it, such as ensuring there is limited access to it and it is encrypted.

How long we hold data: All personal data will only be retained for as long as necessary to fulfil the requirements we have or to satisfy other needs, such as legal, regulatory or reporting needs.

Job Applicants and Staff (past and present)

Please note that we have a legal duty (imposed by the Financial Conduct Authority – FCA) to carry out sufficient due diligence on job applicants and existing staff who are likely to be part of a regulate role.

We may obtain data from you, from multiple sources. For example, from you, from prior employers, from other references, from the internet, from employment agencies, from companies that provide checks like criminal record checks or drug checks.

We may store the following basic personal information about you: name, title, address, telephone number, personal email address, date of birth, gender. We may also retain more detail on your employment history, such as employment history, qualifications, references and other related information. We will also need to identify you and ensure you are able to work for Fundhouse. As such, we will often keep copies of identification documents (passport/driving licence), national insurance number, any next of kin (like close family members). We will also maintain records of any assessments and appraisals of you. This may be obtained by third parties (like your prior employers or other references). We may also store all related job application data, such as your CV, any cover letter, any other relevant information (like your activity on social media). We will also need to likely store financial information, such as your bank details, your salary, any bonuses, taxes, pension and any other related information like student loan deductions. And there will also be data stored about your annual leave.

At times, we may also store more sensitive information, such as your race or ethnicity, your religion, sexual orientation, any disabilities gender, political affiliations as well as information about your health. As part of this, it may include any underlying medical conditions. We will also need to perform further background checks such any criminal convictions and offences. Why do we retain sensitive information? We give some examples. We may use our understanding of your disability to improve the office. We may use your race, religion or gender to fulfil reporting requirements on diversity.

We will not ask your consent to process your data. But we will largely use the data for the following purposes:

  • To evaluate your competence;
  • To assess specific skills;
  • To check your qualifications and your results;
  • To assess your cultural fit;
  • Any background or reference checks;
  • To give you an appraisal;
  • To discuss your remuneration and any related benefits, like bonuses and pension;
  • To provide others with a reference on you (should you leave Fundhouse);
  • Any legal reasons to retain the records or to discuss them;

Securing the data: Where we hold personal data, we will manage the security around it, such as ensuring there is limited access to it and it is encrypted.

Who will see it? We will share your information to the extent it is needed for us to perform our roles. We will not share the information externally unless we are a) doing reference checks, b) doing any checks like a criminal record check or c) we have a legal obligation to share it.

How long we hold data: All personal data will only be retained for as long as necessary to fulfil the requirements we have or to satisfy other needs, such as legal, regulatory or reporting needs.

General Business Contacts

From time to time, we store data of general business contacts. Perhaps we have peers in the industry we keep in touch with, for example. As part of this, we may store some basic information such as your name, title, job, business, address, email address and contact numbers. We will only use your data when it is for legitimate business and/or legal reasons. We will not disclose data to third parties.

International Transfers of your data

We may transfer your personal data outside the European Economic Area (EEA) or the UK. This is for two main reasons. First, we make use of global data storage partners and they have storage servers outside the EEA and the UK. We also have a sister company in South Africa that helps us with our operational support. If your data is sent outside of the EEA, we will only use data providers that we believe provide adequate level of protection.

Data and Information Security

Fundhouse has a comprehensive information security policy. As part of this, we aim to uphold high standards when protecting your personal data. Besides encrypting the data and ensure it is password protected, we also ensure that the providers of our data storage have strong data protection controls, too. We believe that we have strong measures in place that should protect your personal data from being lost, used or accessed. We are happy to share our information security policy with you, so please feel free to request it by emailing us at info@fundhouse.co.uk. Should a breach occur, we will inform you quickly (as well as any regulator).