Regulatory

Introduction:
‍​This privacy notice aims to inform you about how we collect and process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information. It tells you about your privacy rights and how the law protects you.​We are committed to protecting your privacy and the confidentiality of your personal information.

Our policy is not just an exercise in complying with the law, but a continuation of our respect for you and your personal information.​ We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.​ Our policy complies with the Data Protection Act 2018 (Act) accordingly incorporating the EU General Data Protection Regulation (GDPR).

The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at http://www.knowyourprivacyrights.org.​ Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.​We may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 1st January 2020.​

‍Data we process:​
Our company is hosted on the webflow.com platform. webflow.com provides us with the online platform that allows us to sell our products and services to you. Your data may be stored through webflow.com’s data storage, databases and the general webflow.com applications. They store your data on secure servers behind a firewall.​ We may collect, use, store and transfer different kinds of personal data about you. We have collated these into groups as follows:Your identity includes information such as first name, last name, title, date of birth, and other identifiers that you may have provided at some time.​Your contact information includes information such as billing address, delivery address, email address, telephone numbers and any other information you have given to us for the purpose of communication or meeting.​Your financial data includes information such as your bank account and payment card details.​

Transaction data includes details about payments or communications to and from you and information about products and services you have purchased from us.​Technical data includes you internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.​Your profile includes information such as your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.​Marketing data includes your preferences in receiving marketing from us; communication preferences; responses and actions in relation to your use of our services.​ We may aggregate anonymous data such as statistical or demographic data for any purpose. Anonymous data is data that does not identify you as an individual.

Aggregated data may be derived from your personal data but is not considered personal information in law because it does not reveal your identity.​ For example, we may aggregate profile data to assess interest in a product or service.​ However, if we combine or connect aggregated data with your personal information so that it can identify you in any way, we treat the combined data as personal information and it will be used in accordance with this privacy notice.​ Special personal information; Special personal information is data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.​

We may collect special personal information about you if there is a lawful basis on which to do so.​If you do not provide personal information we need;​​​Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform that contract. In that case, we may have to stop providing a service to you. If so, we will notify you of this at the time.​

The bases on which we process information about you​:
The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.​ If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.​Information we process because we have a contractual obligation with you;​When you create an account on our website, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.​ In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.​

We may use it in order to:
verify your identity for security purposes
sell products to you
provide you with our services
provide you with suggestions and advice on products, services and how to obtain the most from using our website

We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.​ We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

​Information we process with your consent​:
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including our products and services, you provide your consent to us to process information that may be personal information.​ Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies.​ If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.​ We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.​ You may withdraw your consent at any time by instructing us at info@mccormackpartners.com. However, if you do so, you may not be able to use our website or our services further.​

Information we process for the purposes of legitimate interests:
We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.​ Where we process your information on this basis, we do after having given careful consideration to:whether the same objective could be achieved through other means whether processing (or not processing) might cause you harm whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so.

For example, we may process your data on this basis for the purposes of:
record-keeping for the proper and necessary administration of our business
responding to unsolicited communication from you to which we believe you would expect a response
protecting and asserting the legal rights of any party
insuring against or obtaining professional advice that is required to manage business risk
protecting your interests where we believe we have a duty to do so​

Information we process because we have a legal obligation;​
‍Sometimes, we must process your information in order to comply with a statutory obligation.​ For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.​ This may include your personal information.​

Information provided on the understanding that it will be shared with a third party:
‍Our website allows you to post information with a view to that information being read, copied, downloaded, or used by other people.​

Examples may include:
posting a message on our forum
tagging an image
clicking on an icon next to another visitor’s message to convey your agreement, disagreement or thanks​

In posting personal information, it is up to you to satisfy yourself about the privacy level of every person who might use it. ​We do store it, and we reserve a right to use it in the future in any way we decide. ​Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time.​ Provided your request is reasonable and there is no legal basis for us to retain it, then at our discretion we may agree to your request to delete personal information that you have posted. You can make a request by contacting us at info@mccormackpartners.com.​

Complaints regarding content on our website:
‍If you complain about any of the content on our website, we shall investigate your complaint.​ If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.​ Free speech is a fundamental right, so we have to make a judgement as to whose right will be obstructed: yours, or that of the person who posted the content that offends you.​ If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.​

Information relating to your method of payment:
‍All direct payment gateways offered by webflow.com and used by our company adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers.​ Payment information is never taken by us or transferred to us either through our website or otherwise. Our employees and contractors never have access to it.​ At the point of payment, you are transferred to a secure page on the website of Stripe or some other reputable payment service provider. That page may be branded to look like a page on our website, but it is not controlled by us.​

Information about your direct debit:
​When you agree to set up a direct debit arrangement, the information you give to us is passed to our own bank (Starling Bank) for processing according to our instructions. We do not keep a copy.​ We are registered under the direct debit guarantee scheme. This provides for the customer's bank to refund disputed payments without question, pending further investigation. Direct debits can only be set up for payments to beneficiaries that are approved originators of direct debits. In order to be approved, these beneficiaries are subjected to careful vetting procedures. Once approved, they are required to give indemnity guarantees through their banks.​

Job application and employment:
‍If you send us information in connection with a job application, we may keep it for up to three years in case we decide to contact you at a later date.​ If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for six years before destroying or deleting it.​

Communicating with us:
When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.​ We record your request and our reply in order to increase the efficiency of our business.​We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.​

Complaining:
When we receive a complaint, we record all the information you have given to us.​ We use that information to resolve your complaint. ​If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.​We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.​

Affiliate and business partner information:
​This is information given to us by you in your capacity as an affiliate of us or as a business partner.​It allows us to recognise visitors that you have referred to us, and to credit to you commission due for such referrals. It also includes information that allows us to transfer commission to you.​The information is not used for any other purpose.​ We undertake to preserve the confidentiality of the information and of the terms of our relationship.​ We expect any affiliate or partner to agree to reciprocate this policy.​

Use of information we collect through automated systems when you visit our website:
​Cookies;​ Cookies are small text files that are placed on your computer's hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.​Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.​

Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.​

Webflow uses cookies for many important reasons, such as:
To provide a great experience for visitors and customers.
To monitor and analyze the performance, operation and effectiveness of Webflow's platform.
To ensure the platform is secure and safe to use.

If you choose not to use cookies or you prevent their use through your browser settings, you will not be able to use all the functionality of our website.​

We use cookies in the following ways:
to track how you use our website You can find more information about cookies here; http://www.allaboutcookies.org/​

You can find more information about the specific cookies we use here; https://support.wix.com/en/article/cookies-and-your-wix-site

‍​The following links explain how to access cookie settings in various browsers:
Cookie settings in Firefox
Cookie settings in Internet Explorer
Cookie settings in Google Chrome
Cookie settings in Safari (OS X)
Cookie settings in Safari (iOS)
Cookie settings in Android
‍
To opt out of being tracked by Google Analytics across all websites, visit this link: http://tools.google.com/dlpage/gaoptout.​

Personal identifiers from your browsing activity:
Requests by your web browser to our servers for web pages and other content on our website are recorded.​We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.​ We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.​ If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed into our website.                      

Our use of re-marketing:
Re-marketing involves placing a cookie on your computer when you browse our website in order to be able to serve to you an advert for our products or services when you visit some other website.​ We may use a third party to provide us with re-marketing services from time to time. If so, then if you have consented to our use of cookies, you may see advertisements for our products and services on other websites.​

Disclosure and sharing of your information​Information we obtain from third parties:​
Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use.​ No such information is personally identifiable to you.​

Data may be processed outside the European Union (as of January 2020):
‍Our websites are hosted in United Kingdom.​ We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business.​ Accordingly, data obtained within the UK or any other country could be processed outside the European Union.​ For example, some of the software our website uses may have been developed in the United States of America or in Australia.​

Control over your own information:
It is your duty to inform us of changes​. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.​

Access to your personal information;​
‍At any time you may review or update personally identifiable information that we hold about you, by signing in to your account on our website.​ To obtain a copy of any information that is not provided on our website you should contact us to make that request.​ After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.​

Removal of your information;​
‍If you wish us to remove personally identifiable information from our website, you should contact us to make your request. This may limit the service we can provide to you.​

Verification of your information;​
‍When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.​

Use of site by children;​
‍We do not sell products or provide services for purchase by children, nor do we market to children.​

Encryption of data sent between us;​
We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.​ Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.​

How you can complain;​
‍If you are not happy with our privacy policy or if you have any complaint then you should tell us.​ If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.​ If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner's Office (ICO). This can be done at https://ico.org.uk/make-a-complaint/. We would, however, appreciate the opportunity to talk to you about your concern before you approach the ICO.​

Retention period for personal data;​
‍Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:
to provide you with the services you have requested;
to comply with other law, including for the period demanded by our tax authorities;
to support a claim or defence in court.  ​

Compliance with the law;​
Our privacy policy has been compiled so as to comply with the law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we should like to hear from you.​ However, ultimately it is your choice as to whether you wish to use our website.​

Review of this privacy policy;​
We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.​

If you have any question regarding our privacy policy, please contact us.

‍IMPORTANT; Our content is intended for informational / educational purposes only and should not be used to replace the advice of a qualified professional. It is not intended to be a substitute for professional advice whether investment related, legal or otherwise. Although we make reasonable efforts to update the information on our site, we make no representations, warranties or guarantees, whether express or implied, that Our Content on the Site is accurate, complete or up to date.

Site Management:
We reserve the right at our sole discretion, to (1) monitor the Site for breaches of these Terms and Conditions; (2) take appropriate legal action against anyone in breach of applicable laws or these Terms and Conditions; (3) refuse, restrict access to or availability of, or disable (to the extent technologically feasible) any of your Contributions; (4) remove from the Site or otherwise disable all files and content that are excessive in size or are in any way a burden to our systems; and (5) otherwise manage the Site in a manner designed to protect our rights and property and to facilitate the proper functioning of the Site and Services.

We do not guarantee that the Site will be secure or free from bugs or viruses. You are responsible for configuring your information technology, computer programs and platform to access the Site and you should use your own virus protection software.

Modifications to and availability of the Site:
‍We reserve the right to change, modify, or remove the contents of the Site at any time or for any reason at our sole discretion without notice. We also reserve the right to modify or discontinue all or part of the Services without notice at any time. We cannot guarantee the Site and Services will be available at all times. We may experience hardware, software, or other problems or need to perform maintenance related to the Site, resulting in interruptions, delays, or errors. You agree that we have no liability whatsoever for any loss, damage, or inconvenience caused by your inability to access or use the Site or Services during any downtime or discontinuance of the Site or Services. We are not obliged to maintain and support the Site or Services or to supply any corrections, updates, or releases. There may be information on the Site that contains typographical errors, inaccuracies, or omissions that may relate to the Services, including descriptions, pricing, availability, and various other information. We reserve the right to correct any errors, inaccuracies, or omissions and to change or update the information at any time, without prior notice.

Disclaimer / Limitation of Liability:
The Site and Services are provided on an as-is and as-available basis. You agree that your use of the Site and/or Services will be at your sole risk except as expressly set out in these Terms and Conditions. All warranties, terms, conditions and undertakings, express or implied (including by statute, custom or usage, a course of dealing, or common law) in connection with the Site and Services and your use thereof including, without limitation, the implied warranties of satisfactory quality, fitness for a particular purpose and non-infringement are excluded to the fullest extent permitted by applicable law. We make no warranties or representations about the accuracy or completeness of the Site’s content and are not liable for any (1) errors or omissions in content: (2) any unauthorized access to or use of our servers and/or any and all personal information and/or financial information stored on our server; (3) any interruption or cessation of transmission to or from the site or services; and/or (4) any bugs, viruses, trojan horses, or the like which may be transmitted to or through the site by any third party. We will not be responsible for any delay or failure to comply with our obligations under these Terms and Conditions if such delay or failure is caused by an event beyond our reasonable control.

Our responsibility for loss or damage suffered by you:
Whether you are a consumer or a business user: We do not exclude or limit in any way our liability to you where it would be unlawful to do so. This includes liability for death or personal injury caused by our negligence or the negligence of our employees, agents or subcontractors and for fraud or fraudulent misrepresentation. If we fail to comply with these Terms and Conditions, we will be responsible for loss or damage you suffer that is a foreseeable result of our breach of these Terms and Conditions, but we would not be responsible for any loss or damage that were not foreseeable at the time you started using the Site/Services. Notwithstanding anything to the contrary contained in the Disclaimer/Limitation of Liability section, our liability to you for any cause whatsoever and regardless of the form of the action, will at all times be limited to a total aggregate amount equal to the greater of (a) the sum of £5000 or (b) the amount paid, if any, by you to us for the Services/Site during the six (6) month period prior to any cause of action arising.

If you are a consumer user:
Please note that we only provide our Site for domestic and private use. You agree not to use our Site for any commercial or business purposes, and we have no liability to you for any loss of profit, loss of business, business interruption, or loss of business opportunity. If defective digital content that we have supplied, damages a device or digital content belonging to you and this is caused by our failure to use reasonable care and skill, we will either repair the damage or pay you compensation. You have legal rights in relation to goods that are faulty or not as described. Advice about your legal rights is available from your local Citizens' Advice Bureau or Trading Standards office. Nothing in these Terms and Conditions will affect these legal rights.

Term and Termination
‍These Terms and Conditions shall remain in full force and effect while you use the Site or Services or are otherwise a user of the Site, as applicable. You may terminate your use or participation at any time, for any reason, by following the instructions for terminating user accounts in your account settings, if available, or by contacting us at info@mccormackpartners.com. Without limiting any other provision of these Terms and Conditions, we reserve the right to, in our sole discretion and without notice or liability, deny access to and use of the Site and the Services (including blocking certain IP addresses), to any person for any reason including without limitation for breach of any representation, warranty or covenant contained in these Terms and Conditions or of any applicable law or regulation. If we determine, in our sole discretion, that your use of the Site/Services is in breach of these Terms and Conditions or of any applicable law or regulation, we may terminate your use or participation in the Site and the Services or delete your profile and any content or information that you posted at any time, without warning, in our sole discretion. If we terminate or suspend your account for any reason set out in this Section 9, you are prohibited from registering and creating a new account under your name, a fake or borrowed name, or the name of any third party, even if you may be acting on behalf of the third party. In addition to terminating or suspending your account, we reserve the right to take appropriate legal action, including without limitation pursuing civil, criminal, and injunctive redress.

General
Visiting the Site, sending us emails, and completing online forms constitute electronic communications. You consent to receive electronic communications and you agree that all agreements, notices, disclosures, and other communications we provide to you electronically, via email and on the Site, satisfy any legal requirement that such communication be in writing. You hereby agree to the use of electronic signatures, contracts, orders and other records and to electronic delivery of notices, policies and records of transactions initiated or completed by us or via the Site. You hereby waive any rights or requirements under any statutes, regulations, rules, ordinances or other laws in any jurisdiction which require an original signature or delivery or retention of non-electronic records, or to payments or the granting of credits by other than electronic means.

These Terms and Conditions and any policies or operating rules posted by us on the Site or in respect to the Services constitute the entire agreement and understanding between you and us.Our failure to exercise or enforce any right or provision of these Terms and Conditions shall not operate as a waiver of such right or provision. We may assign any or all of our rights and obligations to others at any time. We shall not be responsible or liable for any loss, damage, delay or failure to act caused by any cause beyond our reasonable control. If any provision or part of a provision of these Terms and Conditions is unlawful, void or unenforceable, that provision or part of the provision is deemed severable from these Terms and Conditions and does not affect the validity and enforceability of any remaining provisions.

There is no joint venture, partnership, employment or agency relationship created between you and us as a result of these Terms and Conditions or use of the Site or Services.For consumers only - Please note that these Terms and Conditions, their subject matter and their formation, are governed by English law. You and we both agree that the courts of England and Wales will have exclusive jurisdiction expect that if you are a resident of Northern Ireland you may also bring proceedings in Northern Ireland, and if you are resident of Scotland, you may also bring proceedings in Scotland. If you have any complaint or wish to raise a dispute under these Terms and Conditions or otherwise in relation to the Site please follow this link http://ec.europa.eu/odr.

A person who is not a party to these Terms and Conditions shall have no right under the Contracts (Rights of Third Parties) Act 1999 to enforce any term of these Terms and Conditions.In order to resolve a complaint regarding the Services or to receive further information regarding use of the Services, please contact us by email at info@mccormackpartners.com.

The views and opinions expressed in our posts are those of the post’s author and do not necessarily reflect the views of McCormack & Partners, or its affiliates. These posts have been provided solely for informational purposes and do not constitute an offer or solicitation of an offer or any advice or recommendation to purchase any securities or other financial instruments and may not be construed as such. The author(s) makes no representations as to the accuracy or completeness of any information in our posts or found by following any link in any post.