Privacy Policy

Link Fund Solutions Limited ("We") are committed to protecting and respecting your privacy.

This is the privacy policy of the Pensions division of Link Fund Solutions (“LFS”). Throughout this policy, "we", "us" and "our" refer to Link Fund Solutions.

LFS is authorised and regulated by the Financial Conduct Authority (“FCA”).

The main business of Link Fund Solutions is the operation of, and acting as Authorised Fund Manager for, collective investment schemes (including collective investment schemes established for the purpose of providing pension plans). LFS is a wholly owned subsidiary of Link Administration Holdings Limited (“Link Group”). For more information on Link Fund Solutions please visit www.pensions.linkfundsolutions.co.uk. For more information on Link Group, please visit www.linkgroup.com.

What is this Privacy Policy? 

At Link Fund Solutions, we collect personal information about you and are committed to protecting this information and your privacy. Set out below is an explanation of how we use, collect and safeguard your personal information.

What personal information do we collect? 

We may collect information about you in the following ways:

  • As part of your use of our website you have the option on certain pages within this site to submit personal information to us by email, online enquiry or application form. Depending on the services, products or information you request from us, we may ask you to provide the following personal information: 

    • Your name, date of birth, address, email address (optional), telephone number and gender

    • Your National Insurance No

    • Your bank account details

    • Details of transactions you carry out through using our website

  • We also use cookies and your Internet Protocol (IP) address (see section “How do Link Fund Solutions websites use my Internet Protocol (IP) address and collect cookies?” below for further details).

  • We may keep a record of any correspondence you have with us, including any telephone calls which we may have a legal or regulatory obligation to record (we will inform you at the beginning of the telephone conversation if recording will be necessary);

You are not required to supply any of the personal information that we may request. However, failure to do so may restrict or prevent us being able to provide services offered by Link Fund Solutions to you.

Why do we collect your information? 

We collect this information in order for you to use our website and to provide any services to you. In addition, we will use personal information provided by you in order to conduct appropriate checks to enable us to comply with our legal or regulatory obligations and tax reporting. The lawful basis, under the GDPR, for which we process your personal information, is that it is necessary to process your personal information in order to be able to fulfill our contractual obligations to you.

How we use your personal information? 

We will use the information we hold about you for the following purposes:

  • To provide you with the services, products, and/or information you request from us;

  • To check your identity;

  • To assess any application you make to participate in any service we provide;

  • Prevent and detect fraud and/or money laundering;

  • So that we can communicate with you as necessary;

  • To carry out analysis about our services and how we might improve them;

  • To notify you about changes to our services; and

  • Report to regulators and tax authorities.

Who we share personal information with? 

We will only disclose your personal information in accordance with applicable laws and regulations. We will disclose your information to the following third parties:

  • A promoter, investment manager, sponsor, fund manager, administrator or the depositary/trustee (as applicable) of the relevant collective investment scheme

We may disclose your information to the following third parties:

  • Any person with legal or regulatory power over us (such as the Financial Conduct Authority, the Pensions Regulator, police or the Serious Fraud Office) that may require disclosure on legal grounds,

  • HM Revenue & Customs and tax authorities in overseas jurisdictions,

  • Credit reporting agencies for the purposes of verifying your identity,

  • Members of the Governance Advisory Arrangement (GAA) of the relevant pension plan,

  • Service providers engaged by us to help us run our business. Such service providers may include, for example, pension administrators, cloud storage providers (engaged by us to provide electronic storage facilities for our business data and your information), analytical optimization service providers (engaged by us to track and analyze how parts of our website are used by our customers); and or

  • Any member of the Link Group which means our subsidiaries, our ultimate holding company and its subsidiaries (from time to time) as necessary.

Some of these third parties (including Link Group subsidiaries and service providers) may be outside of the European Economic Area (EEA). We will ensure that any such subsidiary or service provider has put in place adequate safeguards to ensure that your information is held securely and in accordance with this Privacy Policy. By submitting your personal data, you agree to the transfer, storing and/or processing of your information by these subsidiaries or service providers.

Revoking Consent  

Where consent has been previously given by you for specific purposes (for example opting to receive information on products, services or additional benefits), you can revoke this consent at any time. It should be noted that by providing the required personal information within your application to join a given pension scheme through us, you accept that it is necessary for us to share your personal details with third parties (including the pension scheme administrator etc.) in order to provide our services to you. If you decide that you no longer wish for us to share your personal details with such third parties, you can revoke your agreement to this by bringing to an end your membership of the pension scheme with us.      

How do we keep your information secure?  

We store the information you provide about yourself in a secure database and take appropriate security measures to protect such information from unauthorised access. For example, we have adopted internal data protection procedures and trained our staff on them with a view to preventing breaches of security. All exchanges of information between you and our website are through encrypted channels designed to prevent the interception and/or misappropriation of your personal and other information.

You recognise that that your use of our website is entirely at your own risk. As Link Fund Solutions websites are grouped to the internet, which is inherently insecure, Link Fund Solutions cannot guarantee the information you supply will not be intercepted while being transmitted over the internet. Accordingly, Link Fund Solutions has no responsibility or liability for the security of personal information transmitted via our website.

How long will we store your information for?  

We generally hold your personal data on our systems for up to 7 years after your last transaction with us to provide any ongoing services to you and discharge our legal and regulatory obligations.

 

Your rights 

You have the following rights in relation to how we use your information. If you’d like to exercise these rights please contact us using the contact details listed at section “Who can you speak to at Link Fund Solutions about this Privacy Policy?” 

  • Right to be informed/Right of access – you have the right to know if we are using your information and, if so, the right to access it and information about how we are using it.

  • Right of rectification – you have the right to require us to rectify any errors in the information we hold about you.

  • Right to erasure (also known as the right to be forgotten) – you have the right to require us to delete your information if our continued use is not justified subject to us being able to do so within the constraints of our record keeping obligations.

  • Right to restrict processing - in some circumstances, although you may not be entitled to require us to erase your information, but may be entitled to limit the purposes for which we can use your information.

  • Right of data portability – you have the right to require us to provide you with a copy of your information in a commonly used machine-readable format or to transfer your information directly to another controller (e.g. a third party offering services competing with ours).

  • Right to object – you have the right to object to processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority, processing for direct marketing (including profiling) and processing for purposes of scientific/historical research and statistics.

 

How do Link Fund Solutions websites use my Internet Protocol address and collect cookies?  

Each time you use our websites, we will automatically collect certain technical information, including the type of browser you use, the IP address used to connect your computer to the internet, and information about your visit, including the full Uniform Resource Locations (URL), clickstream to, through and from our sites, traffic data and other communication data, the resources that you access, and the information derived from the cookies we place on your mobile device and/or computer. In order to improve the quality of our website and services, we may from time to time send your computer a "cookie". Cookies are text files that identify your computer to our server and are stored on your device. Cookies in themselves do not identify the individual user, just the computer used. Cookies enable us to improve your user experience by avoiding the need for you to enter the same information more than once. They also allow us to analyse user behaviour to improve the functionality and performance of our website.

We comply with the EU cookie regulations as introduced in the UK on 25 May 2011 through the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011. There are two types of cookies that can be stored on your device:

  • "session cookies", which only last for the duration of your visit to our website and are automatically deleted from your device when you close your browser; and

  • "persistent cookies", which remain on your device after you have visited our website and are not deleted when you close your browser. Persistent cookies are sent back to our server every time you visit our website.

We make use of session cookies, which are essential to maintain security throughout the site, and are not used for tracking purposes. Session cookies are used to help us remember your movements from page to page, avoiding the need for you re-enter the same information. Session cookies are held in memory and expire when you leave our website.

In addition, in order to develop our site in line with customers’ needs, Link use an analytics and optimization service provided by WT EMEA Acquisitions Ltd (WebTrends) to track and analyse how parts of the site are used. We use this information to help improve the site. The data collected by WebTrends will be stored exclusively for analytical purposes and does not result in any personally identifiable data being collected or stored. WebTrends will send your computer a persistent cookie in order to evaluate your use of this site. WebTrends store the information collected by the persistent cookie on servers in the United States, European Union Member States and other countries. WebTrends may also transfer this information to third parties where required to do so by law, or where such third parties process the information on WebTrends' behalf. WebTrends will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. WebTrends will not associate your IP address with any other data held by WebTrends. Link uses WebTrends to optimise this site and improve the service we provide to our visitors. This ensures that the website is fully functional and optimised to create the best possible user experience.

We do not, nor will we, gather other information from your disk or computer. We will collect a copy of the data held by the cookie from inclusion in any analysis. We use full SSL protocols when collecting visitor information on secure pages; this ensures that the website’s security is not compromised. We encrypt all transmitted visitor information (even from non-secure pages), so no-one else can read the information we gather. None of the cookies used on our websites collect, record or store personally identifiable information about you.

By continuing to use this website, you are consenting to us placing session cookies on your device for the purposes detailed above.  Most users will be able to adjust their internet settings to accept all cookies, to notify them when a cookie is issued, or not to receive cookies at any time. The last of these, of course, means that certain personalised services cannot then be provided to that user. Please note that the websites to which this site may be linked may also make use of their own cookies. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

Following links from our websites  

Our site may contain links to other sites. Such other sites may also make use of their own cookies and will have their own privacy policies. You should carefully review the privacy policies and practices of other sites, as we cannot control or be responsible for their privacy practices. We do not accept any liability for the privacy practices of such third party websites and your use of such websites is at your own risk. 

Changes to this Privacy Policy 

We reserve the right to review, amend and/or update this privacy policy from time to time. Any changes we may make to this Privacy Policy in the future will be posted on this page. 

Who can you speak to at Link Fund Solutions about this Privacy Policy? 

Questions, comments and the exercise of your rights regarding this Privacy Policy and your information are welcomed and should be addressed to us by post at Link Fund Solutions Limited, PO Box 389, Darlington DL1 9UF. Alternatively, you may contact us by telephone on 0345 922 0044 or by fax to 0113 224 6004 or by e-mail at investorservices@linkgroup.co.uk

If you wish to make a complaint about how we have handled your personal information, you can contact us using the details provided above. If you are not satisfied with our response or believe we are processing your personal information not in accordance with the law you may refer a complaint to the Information Commissioner’s Office (the ICO). The ICO is the UK supervisory authority responsible for the implementation and enforcement of data protection law: You have the right to complain to the ICO about our collection and use of your information. You can contact the ICO via its website at www.ico.uk.org/global/contact-us or by calling their helpline on 0303 123 1113 by writing to Information Commissioners Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.

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