The General Data Protection Regulation, known as GDPR, is a really positive step towards you having more control over how your personal data is used and how you’re contacted. This Privacy Policy reflects these regulations and describes Details of what information we collect from you, what we do with it and who it might be shared with. We withhold the right to update this as the law evolves.
Who we are
Our website address is: https://sasetf.com
Personal Data we hold
- Shareholder provided information: Shareholders’ contact details;
- Shareholder account holdings and copies of any relevant legal documents;
- Customer contact records – Records of calls, emails and postal interactions are maintained for audit purposes.
Collection of Data
The data controller is Blue Tractor UK Ltd and Global Financial Solutions Ltd and we use your personal data for the following purposes:
- To administer your Blue Tractor UK Ltd and Global Financial Solutions Ltd Share Holdings (“the Holdings”);
- To communicate with you for any purpose in relation to the Holdings (including new share offering options) by letter, telephone, email or text message.
Legal Basis and Purpose for holding the data
The legal basis and purpose of holding your data is:
- That it is necessary for the function of managing your Holdings (including sending your documents to you, dealing with any administration of the holdings), and
- That by agreeing to this policy you’ve provided consent to us to process your Personal Data to manage your Holdings, and
- That it is necessary for the purposes of the legitimate interests pursued by Blue Tractor UK Ltd and Global Financial Solutions Ltd (including sending you new share offering options or for any other matters arising from the Holdings not covered in the bullet points above).
Transfer of Data to Third Parties
We will only transfer your personal data to third parties to support the administration of your Holdings. These may include:
- Third parties necessary or desirable to manage the legitimate business interests of Blue Tractor UK Ltd and Global Financial Solutions Ltd or as required by law;
- Third parties to administer the Holdings including Administration and Technology Services. They may use your personal data to provide services to you related to the management of your Holdings and may communicate with you by letter, telephone, email or text message.
We will only transfer your data to third parties within the EEA.
Length of time personal data is held
We will update your personal data from time to time based on information received from you directly. In order to comply with tax, financial services regulations and other applicable legislation we will hold your personal data whilst Blue Tractor UK Ltd and Global Financial Solutions Ltd are actively trading and for six years after the stop trading ends at which time it will be destroyed.
For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
Marketing
We may use your personal data for marketing new share offering options (or other similar products) to you in circumstances where this is considered to be appropriate.
Cookies
If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
Updates to this Privacy Policy
From time to time we may make changes to this Privacy Policy and we will update you about these changes via other communications with you and the latest version of this policy will always be available to view on our website – www.sasetf.com
Your rights under Data Protection legislation
You have the right to request from us access to and rectification or erasure of personal data or restriction of processing concerning you and to object to processing. In addition you have the right to data portability. Any questions you may have about data protection should be addressed to the Operations and Compliance Manager at the address below.
You have the right to lodge a complaint with the Information Commissioner’s Office (ico.org.uk).
We may process your personal data for the purposes of its legitimate interests and we may use your personal data for direct marketing, including new share offering options (or other similar products) to you, in circumstances where this is considered to be appropriate.
You have the right to object to processing for direct marketing purposes and for the purposes of Blue Tractor UK Ltd and Global Financial Solutions Ltd legitimate interests.
If you wish to exercise this right, please contact the Operations and Compliance Manager at compliance@sasetf.com.
Embedded content from other websites
Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.
Additional information
How we protect your data
We use a hosting company that uses strong encryption to help ensure privacy and security. It encrypts (serve over SSL) and also 301 redirects all insecure HTTP requests to the secure HTTPS version. It runs firewalls and has processes in place to alert us about unauthorized attempts to access the site. It continuously watches web traffic and monitors suspicious activity. It also has security measures in place to help protect against distributed denial of service (DDoS) attacks. The security of the services are regularly checked for potential vulnerabilities.
What data breach procedures we have in place
We assess and monitor the security of this website. We will notify any affected users within 72 hours of first becoming aware of a security issue.