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In order to access the website of Winterflood Securities Limited you must first read and accept the following terms:

This website is not directed at, or intended for distribution to or use by, any U.S. citizen, person, or entity that resides in or is located in the United States of America or any other jurisdiction where such distribution, publication, availability or use would be contrary to applicable law or regulation which would subject Winterflood to any registration or licensing requirements with such jurisdiction. Services are not available to U.S. persons except where such services are permitted under SEC rule 15a6 or other relevant exemptions from SEC Broker/Dealer registration requirements.

Please note that Winterflood Securities Limited is not registered as a broker-dealer with the Securities and Exchange Commission and is not a member of Financial Industry Regulatory Authority Inc. (“FINRA”). All research reports provided on this website are being distributed directly by Winterflood Securities Limited to persons in the U.S. that qualify as “major U.S. institutional investors” in compliance with Rule 15a-6(a)(2) of the Securities Exchange Act of 1934. Accordingly, these research reports have not been prepared in compliance with FINRA requirements. Please refer to our Full Disclaimer here.

Research on this Website

Research on this website has been issued for the information of Professional Clients and Eligible Counterparties (as defined in the FCA handbook) of Winterflood Securities Ltd (“Winterflood”). The terminology used within the research reports is intended for professional investors. Research reports are not intended to provide the sole basis for any evaluation of an investment decision.

Each research report on this website must be read in conjunction with any disclaimer which forms part of it. Your attention is drawn to the date of issue of the information provided and of the opinions expressed therein. Any opinions are those of the Winterflood Investment Trust research team and are subject to change without notice and Winterflood is not under any obligation to update or keep current the information contained herein. The material on this website is based on information obtained from sources believed to be reliable but which have not been independently verified and are not guaranteed as being accurate.

Use of Cookies

For information on the cookies used on our websites, please refer to our Cookies Policy which can be accessed here.

Privacy

For information on how we treat your personal data, please refer to our Privacy Notice which can be accessed here.

More information can be found in our Legal Disclaimer

If you have read and accepted the terms and conditions for use of this website please click continue

Privacy policy

"We", "our" or "us" means Winterflood Securities Limited and/or Winterflood Securities US Corporation and their subsidiaries. For the purposes of data protection law, we are a controller in respect of your personal data. We collect and use your personal data as described below. We are responsible for ensuring that we use your personal data in compliance with data protection law.

For the purpose of this privacy notice, the terms ‘controller’, ‘process’ and ‘personal data’ shall have the meaning given in relevant data protection legislation (as applicable) and ‘processed’ and ‘processing’ shall be construed in accordance with the meaning of ‘process’.

If you have any questions about this notice, about how we process personal data or about your rights over your personal data, you can contact us via email to dp-enquiries@winterflood.com or dp-enquiries@winterflood.us in the first instance.  Alternatively, our Data Protection Officer can be contacted using the details set out in the “Contact us” section below.

This notice applies to personal data we receive or otherwise create in connection with the provision of services to professional clients / eligible counterparties and their personnel, including any associated services provided via our website(s) at:


www.winterflood.com;
www.winterfloodresearch.com; 
www.winterfloodbusinessservices.com; and/or
www.winterflood.us.

It is important that you take the time to read this notice so that you understand how we will use your personal data and your rights in relation to your personal data.

Personal data that we collect about you

We will collect and use the following information about you:

Information you give us

  • We use the information about you that you provide to us, including the information that you provide when filling in fields in a contract (or related application) or when registering to use sections of our website(s) (such as your name, address, e-mail address, phone number, job title, your preferences for receiving email communications from us) and any other information or updates to your information that you provide to us when corresponding with us (by phone, e-mail or otherwise). 

Information we collect or generate about you

  • When you submit information to us, we may use this information to interact with, and provide services to, you (or your employer), and to carry out our obligations arising under or in connection with a contract.  
  • We may also receive information from other sources for the above purposes.
  • Website usage information – our websites use Google Analytics, VWO, Session Cam and Crazy Egg cookies to automatically gather certain statistical information such as the number and frequency of visitors and their IP addresses. This information is used as aggregated statistical information about users, providing usage by IP address. We do not identify individual users from this type of data and it does not involve the processing of personal data about you. This information helps us to measure how individuals use our websites and our services, so that we can continually improve them. For more information on our use of cookies please refer to our cookies policy on the relevant website(s).
  • We may record, monitor and retain any and all communications (which may include the recording, monitoring and retention by a third party appointed by us), including facsimilie, email and other electronic messaging, telephone conversations and other electronic communications with you, for the purposes of providing services to you (or to your employer) and/or otherwise in order to comply with applicable law. 
  • We generate data for internal analysis and research.

If we do not receive this information we may not be able to provide certain services to you.

How we use your personal data

Your personal data may be processed by us for the following purposes:

  • to provide you with services you request (or services requested by your employer) or other services reasonably ancillary thereto, and to carry out our obligations arising under or in connection with a contract;
  • to administer and maintain user access to our services and/or websites;
  • to communicate with you in relation to the services we provide to you (or to your employer); 
  • to comply with our obligations under applicable law; 
  • to monitor and improve our websites and services; and/or
  • for internal analysis and research.

Legal basis for processing your personal data

We process your personal data pursuant to the following legal bases:

(i) where necessary to comply with a legal obligation (for example anti-money laundering, know-your-customer and counter-terrorist financing checks and the prevention and detection of fraud and other financial crime);

(ii) where necessary for the purpose of our legitimate business interests which includes:

  • the provision of services to you (or your employer), the sending and receipt of communications in relation thereto and/or carrying out obligations arising in connection with a contract;
  • compliance with legal and regulatory obligations (including applicable laws, rules and regulations outside of the United Kingdom) and requests or requirements of competent authorities (including those outside of the United Kingdom);
  • contacting you with email updates in relation to services;
  • generating data for internal analysis and research (including monitoring and improving our websites and services);
  • marketing Winterflood’s products and services, including event invitations and the sending of branded merchandise; and
  • keeping a record of what individuals are interested in hearing about from us; or

(iii) where you have separately consented for us to use your personal data to send you specific email updates and communications (by opting-in to such email updates/ communications).

You have the right to object to processing under (ii) by contacting us using the details set out in the “Contact us” section below, and you may cancel your subscription under (iii), at any time by using the ‘unsubscribe’ link within the communications you receive from us or by emailing us at unsubscribe@winterflood.com and requesting the same.

Please note that any instruction to unsubscribe from communications will not affect any processing pursuant to (i) in relation to compliance with a legal obligation.

Sharing your personal data

We may disclose your personal data to our affiliates (being any subsidiary undertaking or parent undertaking, or a subsidiary of any parent undertaking of ours, as the same terms are defined in the Companies Act 2006) and to third party service providers in the circumstances described below:

  • in relation to our legitimate business interests (as above);
  • to facilitate the administration and maintenance of user access to our services and/or websites;
  • to conduct and/or improve our business development activities; and
  • to ensure the safety and security of our data (and that of third parties, including data vendors and other data sources).

We will take steps to ensure that the personal data is accessed only by persons that have a need to do so for the purposes described in this notice.

We may also share your personal data with third parties:

  • if we sell any of our business or assets, in which case we may disclose your personal data to the prospective buyer for due diligence purposes;
  • if we are acquired by a third party, in which case personal data held by us about you will be disclosed to the third party buyer;
  • to third party agents or contractors (for example, the providers of our electronic data storage services) for the purposes of providing services to us; and
  • with your consent, to our affiliates who may wish to offer you products and services which may be of interest to you.

These third parties will be subject to confidentiality requirements and they will only use your personal data as described in this notice.

We may also share your personal data with third parties (including, without limitation, regulatory, governmental, judicial and other bodies or authorities of competent jurisdiction) to the extent required by applicable law, for example if we are under a duty to disclose your personal data in order to comply with any legal or regulatory obligation, and to establish, exercise or defend our legal rights.

Transfer of personal data outside the United Kingdom

The information you provide to Winterflood Securities Limited will be transferred to and stored on our secure servers in the United Kingdom (“UK”). However, from time to time, your personal data may be transferred to, stored in, or accessed from a destination outside the UK or EEA (as applicable). It may also be processed by staff operating outside of the UK who work for us or an affiliate or for one of our suppliers. 

The information you provide to Winterflood Securities US Corporation will be transferred to and stored on our secure services in the United States of America.

Where we transfer your personal data outside the UK or EEA (as applicable), we will ensure that it is protected in a manner that is consistent with applicable data protection laws in the UK or EEA (as applicable). This can be done in a number of ways, for instance:

  • the country that we send the data to might be approved by the UK government or European Commission (as applicable) or a relevant data protection authority (as offering equivalent protections to those afforded in the UK or EEA (as applicable)); 
  • the recipient might have signed up to a contract based on “standard contractual clauses” approved by the UK government or European Commission (as applicable), obliging them to protect your personal data; or
  • in other circumstances where permitted in accordance with applicable law, rule or regulation. 

In all cases, however, we will ensure that any transfer of your personal data is compliant with data protection law. 

You can obtain more details of the protection given to your personal data when it is transferred outside the UK or EEA (as applicable) (including a copy of the standard contractual clauses which we have entered into with recipients of your personal data) by contacting us in accordance with the “Contact us” section below.

How long we keep your personal data

How long we hold your personal data for will vary. The retention period will be determined by various criteria including:

  • the purpose for which we are using it – we will need to keep the data for as long as is necessary for that purpose (for example, to communicate with you in respect of our services for so long as you (or your employer) remain a recipient of such services); and/or
  • legal and regulatory obligations – applicable laws, rules or regulations may set a minimum period for which we have to store your personal data.

Your rights

You have a number of rights in relation to the personal data that we hold about you. These rights include:

  • the right to object to our processing of your personal data where we process your personal data pursuant to our legitimate business interests. Please note that there may be circumstances where you object to our processing of your personal data but we are legally entitled to refuse that request;   
  • the right to obtain information regarding the processing of your personal data and access to the personal data which we hold about you;
  • the right to withdraw your consent to our processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason (other than consent) for doing so; 
  • in some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that we transmit such data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to us;
  • the right to request that we rectify your personal data if it is inaccurate or incomplete;
  • the right to request that we erase your personal data in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal data but we are legally entitled to retain it;
  • the right to request that we restrict our processing of your personal data in certain circumstances. Please note that there may be circumstances where you ask us to restrict our processing of your personal data but we are legally entitled to refuse that request; 
  • the right to object to the processing of your personal data for direct marketing purposes; and
  • the right to lodge a complaint with the data protection regulator (details of which are provided below) if you think that any of your rights have been infringed by us.

You can exercise your rights by contacting us using the details set out in the “Contact us” section below. You can find out more information about your rights by contacting the data protection regulator, the Information Commissioner, or by visiting their website at https://ico.org.uk/.

Changes to this Privacy Notice

We keep this notice under regular review. Any changes we make to this notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to this notice.

Contact us

Winterflood Securities Limited is a company registered in England and Wales with registered company number 02242204 (registered with the UK Information Commissioner under Z4851407) whose registered address is at The Atrium Building, Cannon Bridge House, 25 Dowgate Hill, London, EC4R 2GA. 

Please contact us if you have any questions about this notice or personal data that we may hold about you:

  • By post: to the address above, marked for the attention of the Data Protection Team;
  • By telephone: 0203 100 0000; or
  • By email: dp-enquiries@winterflood.com.

Winterflood Securities US Corporation is a company registered in Delaware, USA with registered company number 6982173 (registered with the UK Information Commissioner under ZB281037) whose principal place of business is at 1460 Broadway, New York, NY, 10036, USA. 

Please contact us if you have any questions about this notice or personal data that we may hold about you:

  • By post: to the address above, marked for the attention of the Data Protection Team;
  • By telephone: 917-382-1796; or
  • By email: dp-enquiries@winterflood.us.

You can also contact our Data Protection Officer using the following details:

  • By post: Data Protection Officer, Close Brothers, 10 Crown Place, London EC2A 4FT;
  • By telephone: 0333 321 6100; or
  • By email: dpo@closebrothers.com