Who should read this policy: Everyone who visits our website at https://www.enfortitude.com/ (Website), as well as customers and prospective customers of our business and their staff, or if you are an alternative business contact, such as a supplier or service provider to our business, or a referral partner.
What is covered: This policy sets out what information we collect about you, what we use it for and who we share it with. It also explains your rights and what to do if you have any concerns about your personal data.
Who to contact about this notice: If you have any questions about this privacy policy, how we handle your personal data or you are looking to exercise one of your rights, please contact: hello@enfortitude.com
Latest updates: This policy was last updated 6 May 2022. We may sometimes need to update this policy to reflect changes to the way we provide our services or to comply with updates to data protection law. Where possible, we will notify you of any substantive changes but please check back regularly to see whether any changes have occurred.
Who checks this policy is enforced: The Information Commissioner’s Office (ICO) is the UK regulator and is responsible for checking that businesses comply with UK data protection law.
We are Enfortitude Ltd, registered in England and Wales with company number 132823582 whose registered address is 1-3 Gloucester Road, Bishposton, Bristol, BS7 8AA (we / us /our).
For the purposes of UK data protection law, we are the controller of your information (which means we decide what information we collect and how it is used). We are registered with the Information Commissioner’s Office (ICO), the UK regulator for data protection matters, under number ZB330576.
If you have any questions about this privacy notice or the way that we use information, please get in touch using the following details:
Email address: hello@enfortitude.com
Postal address: 1-3 Gloucester Road, Bishposton, Bristol, BS7 8AA
Personal data means any information which does (or could be used to) identify a living person. We have grouped together the types of personal data that we collect and where we receive it from below:
Identity Data – your first and last name or title, nationality and residency status, copy of passport or driving licence, recent utility bills or bank statements
Contact Data – your email address, telephone numbers, home address
Investment Data – how much cash you have to invest, how soon you would like to invest, your investment goals
Property Data – properties which you are considering investing in, or have invested in, mortgage information
Financial Data – (other than in relation to your investments) such as your tax status (including your place of domicile), your bank details for payment purposes, payslips (as proof of income)
Feedback – information and responses you provide when completing surveys and questionnaires
Marketing and Communication Data – includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Technical Data – internet protocol (IP) address, browser type and version, time zone setting and generic location, browser plug-in types and versions, operating system and platform on the devices you use to access our systems
Usage Data – information about how you use our systems
Under UK data protection law, we need a legal reason (known as a lawful basis) for holding, collecting and using your personal data. There are 6 main legal reasons which organisations can rely on. The most relevant are:
The following table sets out when we rely on each lawful basis.
Contract
Legal Obligation
Legitimate Interests
Where using your information is necessary to pursue our legitimate business interests to:
Where we use your information for our legitimate interests, we have assessed whether such use is necessary and that such use will not infringe on your other rights and freedoms.
Consent
Where we need to collect your personal data (for example, in order to fulfil a contract we have with you), failure to provide us with your personal data may mean that we are not able to provide you with the services. Where we do not have the information required about you to fulfil an order, we may have to cancel the service ordered.
If you have consented to receiving marketing messages from us, you can opt out of these at any time. Just let us know at hello@enfortitude.com.
Opting out of marketing will not affect our processing of your personal data in relation to any contract you have with us where we are required to use your personal data to fulfil that contract or provide you with certain information.
Where you have used our services before, we may use your information to send you marketing messages about similar services that we think (based on the information you have provided us) would be of interest to you. If you no longer wish to receive these messages, you can opt out at any time by clicking ‘unsubscribe’ in the message or by emailing hello@enfortitude.com.
We may share your personal data with:
If we were asked to provide personal data in response to a court order or legal request (e.g. from the police), we would seek legal advice before disclosing any information and carefully consider the impact on your rights when providing a response.
We store company information (including your personal data) in servers located in the United Kingdom.
We will only transfer information outside of the UK or the EU where we have a valid legal mechanism in place (e.g. by using contracts approved by the European Commission or UK Secretary of State).
We have put in place appropriate security and safety measures to prevent your personal data from being lost or illegally accessed by those who do not have permission.
In the event that there is an event or incident affecting your personal data, we will keep you informed. We may also need to notify the regulator (where required under data protection law) and if we make decisions about personal data about your data jointly with another party (for example, if a third party marketing provider), we may need to notify them.
Where we are responsible for making decisions about how to collect and use your personal data, we will only keep your personal data for as long as necessary to fulfil the purposes we collected it for or as long as required to fulfil our legal obligations.
When we consider how long to keep your personal data, we will consider whether it is still necessary to keep it for the purpose which we collected it or whether the same purpose could be achieved by holding less personal data. We will also consider the volume, nature, and sensitivity of the personal data and the potential harm to you if there was an incident affecting your personal data.
We may keep Identity Data, Contact Data and certain other data (specifically, any exchanges between us by email or any other means) for up to seven years after the end of our contractual relationship with you.
If you browse our Website, we keep personal data collected through our analytics tools for only as long as necessary to fulfil the purposes we collected it for (see our cookie policy below for further information).
If you have asked for information from us or you have subscribed to our mailing list, we keep your details for a reasonable time or until you ask us to stop contacting you.
You have specific legal rights in relation to your personal data.
We can decide not to take any action in relation to a request where we have been unable to confirm your identity (this is one of our security processes to make sure we keep information safe) or if we feel the request is unfounded or excessive. We may charge a fee where we decide to proceed with a request that we believe is unfounded or excessive. If this happens we will always inform you in writing.
Your legal rights are as follows:
Access: You must be told if your personal data is being used and you can ask for a copy of your personal data as well as information about how we are using it to make sure we are abiding by the law.
Correction: You can ask us to correct your personal data if it is inaccurate or incomplete. We might need to verify the new information before we make any changes.
Deletion: You can ask us to delete or remove your personal data if there is no good reason for us to continuing holding it or if you have asked us to stop using it. If we think there is a good reason to keep the information you have asked us to delete (e.g. to comply with regulatory requirements), we will let you know and explain our decision.
Restriction: You can ask us to restrict how we use your personal data and temporarily limit the way we use it (e.g. whilst you check that the personal data we hold for you is correct).
Objection: You can object to us using your personal data if you want us to stop using it. We always comply with your request if you ask us to stop sending you marketing communications but in other cases, we decide whether we will continue. If we think there is a good reason for us to keep using the information, we will let you know and explain our decision.
Portability: You can ask us to send you or another organisation an electronic copy of your personal data.
Complaints: If you are unhappy with the way we collect and use your personal data, you can complain to the Information Commissioner or another relevant supervisory body, but we hope that we can respond to your concerns before it reaches that stage. Please contact us at hello@enfortitude.com.
If you would like to exercise any of your legal rights, please contact: hello@enfortitude.com.
Our Website uses cookies and similar technologies.
Cookies are small text files that are downloaded to your device. Cookies contain uniquely generated references which are used to distinguish you from other users. They allow information gathered on one webpage to be stored until it is needed for use on another, allowing our Website to provide you with a personalised experience (like remembering your favourites) and provide us with statistics about how you interact with our Website.
Cookies are not harmful to your devices (like a virus or malicious code) but some individuals prefer not to share their information (for example, to avoid targeted advertising).
Different types of cookies
Session vs. persistent cookies: cookies have a limited lifespan. Cookies which only last a short time or end when you close your browser are called session cookies. Cookies which remain on your device for longer are called persistent cookies (these are the type of cookies allow websites to remember your details when you log back onto them).
First party vs third party cookies: cookies placed on your device by the website owner are called first party cookies. When the website owner uses other businesses’ technology to help them manage and monitor their website, the cookies added by the other business are called third party cookies.
Categories of cookies: cookies can be grouped by what they help the website or website owner do (the Purpose).
What do we use cookies for?
We use cookies to:
We can only use cookies with your permission (you will be prompted by a message when you first visit our Website, also known as a cookie banner, where you can choose to accept or decline our cookies).
You can choose to decline cookies but if you turn off necessary cookies, some pages and functions on our Website may not work properly. You can also manage cookies through your browser settings or device settings (your user manual should contain additional information).
We use cookies for the following services :
You can also delete cookies directly with the relevant third parties (for example, you can disable Google Analytics on their website).
