As the operators of various products, services and websites (“CT Services”), Creative Technologies Limited ("We", “Us”) is committed to protecting and respecting your privacy. This Privacy and Cookies Policy (“Policy”) (together with and any other documents referred to therein) sets out the basis on which the personal data collected from you, or that you provide to Us will be processed by Us. Please read the following carefully to understand our views and practices regarding your personal data and how We will treat it.
For the purpose of the General Data Protection Regulation (“GDPR”, from the GDPR implementation date) or, until GDPR implementation date, the Data Protection Act 1998, (collectively the “Data Protection Laws”) the Data Controller is Creative Technologies Limited.
IMPORTANT NOTE TO USERS OF THE WEALTH PLATFORM: Creative Technologies Ltd is a technology developer and supplier, not a financial adviser. Creative Technologies does not provide any financial advice to you whatsoever. Creative Technologies developed and hosts Wealth Platform for the benefit of your Adviser to facilitate their management of your information and documentation as part of the financial management services the Adviser has agreed to provide to you pursuant to your Adviser Agreement.
Information we collect from you
We collect and process some or all of the following types of information from you:
For certain CT Services, the provision of your full name, postcode, e-mail address, date of birth, gender, health status, PEP status, salary and other information relating to your assets and liabilities are all required from you in order to register you on a CT Service.
When submitting general enquiries through a CT Service (e.g. Our website), your name, e-mail address and contact number are required from you to enable Us to respond to your enquiry.
We will inform you at the point of collecting information from you, whether you are required to provide any other information to Us.
Lawful basis for processing
We rely on the fulfilment of Our contractual obligations as the lawful basis for processing your personal data. This may be pursuant to any terms and conditions or end user licence agreements you have entered into with Us.
We also rely on “legitimate interests” for processing your personal data. The legitimate interest is processing your personal data as part of the performance of Our contract with your Adviser or is responding and contacting you regarding any enquiries you make in relation to the CT Services We offer
Purposes of processing
We use information held about you in the following ways:
In addition to the above uses We may use your personal data to notify you about additional CT Services which may be of interest to you. For such uses We will only contact you by electronic means (e-mail) if you have provided Us with your email address when We collect your personal data.
If you do not want Us to use your personal data in this way please either (i) tick the relevant box situated on the form or page on which We collect your personal data (for example, a registration form or a website page); (ii) unsubscribe from our electronic communications using the method indicated in the
relevant communication; or (iii) inform Us at any time by contacting Us at the contact details set out below.
Third Party Marketing
We will not sell, share or pass your personal data to a third party for marketing purposes unless you have expressly consented to Us doing so.
Your personal data will be disclosed to your adviser.
We may pass your personal data to our third party service providers, agents, subcontractors and other associated organisations for the purposes of: (i) completing tasks and providing services to you on our behalf (e.g. to host our servers) and (ii) storing, protecting and securing your personal data.
We may disclose your personal data to any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 (where applicable).
We may also disclose your personal data to third parties:
Other than as set out above, and save insofar as is necessary in order for Us to carry out Our obligations arising from any contracts entered into between you and Us, We will not share your data with third parties unless We have procured your express consent to do so.
We take appropriate measures to ensure that any personal data are kept secure, including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data 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. Where We have given you (or where you have chosen) a password which enables you to access certain parts of a CT Service, you are responsible for keeping this password confidential.
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.
Unfortunately, the transmission of information via the internet is not completely secure. Although We will do Our best to protect your personal data, We cannot guarantee the security of your data transmitted to a CT Service; 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.
Keeping your personal data up to date
If your personal details change you may update them by contacting your Adviser. With certain CT Services, you may update your personal data by contacting Us directly using the contact details below. If you are unsure as to who you should contact, We will endeavour to advise you accordingly. If you have any questions about how We use data collected which relates to you, please contact Us by sending a request by email to the contact details below.
Where you have contacted Us regarding an update to your personal data and We agree that this should be dealt with by Us as opposed to your Adviser, We will endeavour to update your personal data within 14 working days of any new or updated personal data being provided to Us, in order to ensure that the personal data We hold about you is as accurate and up to date as possible.
How long we keep your personal data
Where we store your personal data
All information We hold about you is stored on our secure servers within the EEA.
The data that We collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). 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 held securely and in accordance with this Policy. Countries outside the EEA do not have the same data protection laws as the United Kingdom and EEA and we have therefore ensured that any of our suppliers who may transfer your personal data outside the EEA has put in place appropriate measures to protect your data, either by being a member of the US-EU Privacy Shield, or by entering into a European Commission approved contract (as permitted under Article 46(5) of the General Data Protection Regulation).
If you would like further information please contact Us using the details below. We will not otherwise transfer your personal data outside of the EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
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:
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 at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
We reserve the right to modify this Policy at any time. Any changes We may make to Our Policy in the future will be notified and made available to you using the applicable CT Service or via Our website. Your continued use of the CT Services shall be deemed your acceptance of the varied Policy.
We may collect information about your mobile phone, computer or other device from which you access any of the CT Services including where available your IP address, operating system and browser type, for systems administration. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual. We may, however, use such information in conjunction with the data We have about you in order to track your usage of our services.
A cookie is a small file of letters and numbers that We store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
The cookies we use for Our Wealth Platform:
|Cookie||Name||Purpose||Expires / Max. age|
|Session tracker||.AspNetCore.Antiforgery.K4LTrkrUsso||Antiforgery Token - XSS protection||Session tracker|
|Session tracker||.AspNetCore.Session||Session Variables||Session tracker|
|Google Analytics||_ga||Google Analytics||Google Analytics|
|Google Analytics||_gid||Google Analytics||Google Analytics|
|WAF||BNES_.AspNetCore.Antiforgery.2fWDgIFqWMc||Encrypts the cookie through firewall||Session tracker|
|WAF||BNES_ct.tokenserver||Encrypts the cookie through firewall||Session tracker|
|WAF||BNES_DeviceId||Encrypts the cookie through firewall||Device ID|
|WAF||BNES_idsrv.session||Encrypts the cookie through firewall||Session tracker|
|WAF||BNES_samesite||Encrypts the cookie through firewall||Session tracker|
|WAF||BNI_persistence||Encrypts the cookie through firewall||Session tracker|
|Session tracker||ct.tokenserver||Securely identifies for a given login session||Session|
|Device ID||DeviceId||Identifies device||Device ID|
|Session tracker||idsrv.session||Securely identifies for a given login session||Session tracker|
The cookies we use for the Creative Technologies website
|Cookie||Name||Purpose||Expiry of Cookie and Further Information|
|ANONID1085817||Usually is used in conjunction with VISID cookie for the same purpose||1 year|
|ANONID_FS10858 17||ANONID_FS hold only the creation date of the ANONID cookie.||1 year|
|5w4iaviw w0jpzigk4f amhbgx||ASP.NET_SessionI d||System session cookie||Session|
4be2- ba8b- 42861221
aa15#ww w.ctonewo rld.com#0 9.05.2018
|VISID1085817||This track visit session identifier which is used to aggregate page usages. It is actually used in all front end pages||30 mins|
|desktop||visitorDeviceClass||Identifies if the visitor uses a tablet/iPhone/Desktop to display the dedicated layout of the site||Session|
All questions, comments and requests regarding this Privacy and Cookies Policy should be addressed to firstname.lastname@example.org write to Us at FAO Support Manager , Creative Technologies, Holmwood House Broadlands Business Campus, Langhurstwood Road, Horsham, West Sussex, RH12 4QP.
For new sales enquiries, please call 01403 334411
For all other enquiries, please call 01403 334455