YourCAM Privacy Policy

When you access the YourCAM portal or app, the data is managed by a company called moneyinfo limited. This is the privacy policy that will apply to how we and moneyinfo deal with the information that they hold because of your use of the portal and app. It sets out the basis on which the personal or other data collected from you by City Asset Management Plc (‘CAM’, ‘we’ or ‘us’), or that you provide to moneyinfo limited (‘moneyinfo’), will be protected by us and how that information will be used. It describes the kinds of information we may collect from or about you, how we use that information and your rights to access and control our use of your information.

1. The privacy & security of your data

The security and privacy of your information is extremely important to us, and we have implemented appropriate technical and organisational security measures to ensure that your information is protected.

We use data and password encryption and the latest in electronic and physical security measures to give you the best possible protection. All information is securely transmitted using SSL standard encryption which creates an encrypted connection between your browser and our servers. Your information remains encrypted at all times.

Our servers are located in a secure facility that is protected by the very best in physical security, electronic security and internal security policies to ensure that your data remains secure. Security personnel monitor the system 7 days a week, 24 hours a day and access requires multiple levels of authentication.

We are committed to maintaining the confidentiality, integrity, and security of any personal or other information about our users.

 

2. Purpose and legal basis for holding data

All data is held securely under the provisions of the relevant data protection law, which includes the General Data Protection Regulation, and data is provided for you for the purposes of viewing and managing your financial information.

YourCAM is supplied to you by CAM through moneyinfo ltd who acts as our agent for that purpose. moneyinfo are processing your personal data under the strict understanding that you have given explicit consent do so to moneyinfo. You may withdraw this consent at any time by notifying either us or moneyinfo.

 

3. Raising a Concern

If you have any concerns in connection with your data and its processing via YourCAM or if you think any data held within YourCAM may be inaccurate or incomplete then please contact CAM by emailing clientservices@city-asset.co.uk or calling 0207 324 2920. moneyinfo act as Data Processor under data protection law, so you may also contact moneyinfoby email at enduserservices@moneyinfo.com, by telephone 03303 600300 or by writing to us at moneyinfo Ltd, Forward House, 17 High Street, Henley-in-Arden, Warwickshire B95 5AA.

Where you have added your own data to moneyinfo and hidden it from view by CAM using the privacy controls available to you, then in these circumstances moneyinfo would be the Data Controller you should contact moneyinfo using the contact details above for any questions in connection with data you have added.

If you have a concern or would like to lodge a complaint against either CAM or moneyinfo please first inform CAM by telephoning or emailing us using the details above. You may also raise your concern with the Information Commissioner’s Office (ICO). You may be eligible for compensation for damages caused if we breach of our responsibilities. For information on how to raise your concern with the ICO please see https://ico.org.uk/concerns/.

 

4. What information is held about you?

We hold personal information and other data in moneyinfo as is necessary to provide you with the YourCAM service. Most of the personal information we process is provided to us directly by you, either you have added it directly to YourCAM or moneyinfo have captured the information previously and imported it from other systems they may use. CAM will also provide information about you and your portfolios.

All data held about you within the moneyinfo database is encrypted and securely stored and retained whilst you continue to be subscribed to the service. The data held is visible to you via the moneyinfo service and you have control over who can access any data you add yourself.

The type of personal information we collect and hold includes:

  • Personal identifiers, contacts, and characteristics (for example, your name, national insurance number and contact details).

  • Demographic information such as your date of birth, gender, or marital status.

  • Details about your work, nationality, or your tax status.

  • Financial information such as your income, expenditure, assets, or liabilities.

  • Personal details about you that are stored in documents that you may have uploaded to the service.

  • Information that allows us to understand how you use our services e.g., from your log in history or page visits.

We may also collect certain information about you and your use of our service by using cookies and other tracking technologies. This will record information such as your IP address, domain names, the web browser and operating system used to access our website, your location and browsing history, including the pages visited, the time spent on each page and the time and date of each visit. This information is used to measure the use of our service and improve its content and would not be used to identify you.

For more information about how and why we use cookies and how you can change your cookie settings, please see our Cookie Policy below.

 

5. How moneyinfo use your data.

moneyinfo may only use information that they hold in the following circumstances:

  • To enable them to provide the YourCAM service to you as detailed in the YourCAM terms.

  • To analyse how the YourCAM service is being used so that they can improve the service.

  • To alert you to service changes and updated information.

  • To troubleshoot problems, detect and protect against error or criminal activity such as fraud.

  • To share with third-party contractors that provide integrated services to moneyinfo (such as data feeds to value your investments) and are bound by these same privacy restrictions.

  • For benchmarking and data analysis purposes.

  • To enforce the YourCAM terms and comply with the terms of this privacy policy.

moneyinfo reserve the right to use, sell, rent, license, distribute and disclose aggregated data which has been created by combining information that moneyinfo have collated from multiple sources and anonymised. moneyinfo will not sell or rent your data to any third-party other than as aggregated data.

 

6. Your data belongs to you and you can delete your data at any time.

Your data is yours. You can request it is removed from YourCAM at any time. When you request us to delete your account from YourCAM, your data will be permanently deleted from moneyinfo’s primary production servers and further access to your account will not be possible. This deletion will disconnect any connection moneyinfo had established to your account information. However, portions of your data, consisting of aggregated data derived from your account information, may remain on moneyinfo’s production servers indefinitely. Your data may also remain on a moneyinfo’s backup server or media for a limited period whilst backup cycles complete. moneyinfo keeps backup data to ensure that they can continue to provide the service to you in the unlikely event of malfunction of their primary production servers. moneyinfo also reserve the right to retain and use any aggregated data derived from or incorporating your information.

If you have any queries about how we use your personal data, please contact clientservices@city-asset.co.uk in the first instance or you can email moneyinfo on support@moneyinfo.com.

 

7. Why you should not solely rely on the information contained in YourCAM.

The content on YourCAM is provided for general information only. Whilst every effort is made to ensure that the information contained on YourCAM is accurate and up to date, we and moneyinfo cannot accept any responsibility for the accuracy of the underlying data.

You should not rely on the information on YourCAM to decide upon or undertake transactions or financial decisions or use it for tax reporting or insurance purposes. You must obtain professional or specialist advice from your financial adviser before taking, or refraining from, any action or financial decision. Use of YourCAM does not constitute advice and moneyinfo are neither qualified nor permitted by law to advise you in relation to financial matters.

We and moneyinfo make no representations, warranties or guarantees, whether express or implied, that the content on moneyinfo is accurate, free from errors or omissions, complete or up-to-date.

 

8.  How information is retrieved from third-parties.

To provide elements of the service to you, moneyinfo use third-party data processors. They have contracts in place with these data processors that ensures they cannot do anything with your personal information unless instructed by moneyinfo. They will not share your personal information with any organisation apart from moneyinfo. They will hold it securely and retain it only for the period that moneyinfo instructs.

 

9. Data accuracy within moneyinfo.

The information displayed in moneyinfo is only as up to date as the information supplied to us by third party sites, providers and moneyinfo ltd. Neither moneyinfo nor CAM check the data received from third parties for accuracy and the information displayed may be more up to date when obtained directly from the relevant parties.

CAM and moneyinfo do not assume responsibility for the timeliness, accuracy, deletion, non-delivery, or failure to store any user data, communications, or personalisation settings.

 

10. Who will your data be shared with?

Data is visible by you and any related parties linked to you. You can set privacy on any data you add yourself and choose which related parties you wish to share your data with. Your data may be shared with our staff and the staff of moneyinfo as necessary to provide YourCAM to you and in our capacity as your financial adviser and investment manager.

 

11. Controlling your Privacy Settings

You can directly control who can view any of the data which you have added to YourCAM by use of the privacy control settings. See my privacy settings by clicking on the Me icon within YourCAM.

 

12. moneyinfo Limited employees can access your data only in strictly safeguarded circumstances

moneyinfo Limited employees do not have direct access to the moneyinfo database except where necessary for system management, maintenance, monitoring, and backups. In this scenario, only specific nominated individuals have access. Such access is only given and used in accordance with strict internal procedures, in order to operate, develop or enhance the Service. These individuals have passed stringent employment vetting checks and are bound by confidentiality obligations and are subject to disciplinary procedures, including termination of employment and potentially criminal prosecution if they fail to meet these obligations.

 

13. Your log-in credentials are kept secure and encrypted in the moneyinfo Service.

Any other online login username, passwords, or security numbers you enter into the moneyinfo service will never be accessible to any employee of moneyinfo ltd limited or anyone from moneyinfo Limited. This information is kept separately from the moneyinfo service and your other personal data as an additional security measure.

You are responsible for ensuring that your login credentials are kept secure and not disclosed to any other party. If you feel your log in credentials have been obtained by another party, you should change your password immediately.

 

14. Disclosure of your information to protect our rights or if required by law.

Notwithstanding anything to the contrary, moneyinfo and CAM reserve the right (and you authorise us) to share or disclose your information at our sole discretion, should we deem that the disclosure of such information is necessary or appropriate:

  • To enforce our rights against you or in connection with a breach by you of our privacy or security policies or the YourCAM terms.

  • To prevent prohibited or illegal activities.

  • When required by any applicable law, regulation or other legal process.

 

15. Other information regarding your data.

 

15.1. Marketing and other notices.

You can change your marketing preferences within the settings section of YourCAM to manage your email preferences and opt-out of education, marketing, and service notifications. To access these settings, click on the Me icon and select settings from the pop-up menu.

 

15.2. Deletion of Documents

Documents you upload to moneyinfo can be deleted by you, us and moneyinfo Limited. Once deleted, they are removed from YourCAM and moneyinfo’s systems and moneyinfo do not retain copies.

 

15.3. Cookies and how we use online session information.

moneyinfo may store information about you in a cookie (a small file that is sent by our web server to your computer), which we can access when you make return visits to YourCAM. Storing cookies is usual practice for any web site that needs to remember what its users' preferences are and CAM and moneyinfo use cookies to keep track of your choices in YourCAM. Our cookies are encoded so that they can only be accessed by us. If you would like to delete any cookies that are already on your computer, please refer to the instructions for your file management software to locate the file or directory that cookies are stored in. If you would like to stop cookies being stored on your computer in the future, please refer to your browser manufacturer's instructions by clicking ‘Help’ in your browser menu. Further information about deleting or controlling cookies is available at www.aboutcookies.org.

Moneyinfo may collect information when you visit moneyinfo such as the pages you have visited, your browser type or the average time you have spent on the site. Please note that when you visit our site, we may also log your IP address, a unique identifier for your computer or other access device. This information is only analysed and used to improve the design or functionality of the service or to alert you to any compatibility issues.

We use cookies to enhance the security of the service and to compile anonymous statistics about the use of the service. Here is a list of the main cookies that we use and what they are used for:

15.3.1 .NativityAuth (Session Cookie)

This cookie is strictly necessary for the website to function correctly. It remembers the user who logged in to the system. It is removed when the browser is closed.

15.3.2 RequestVerificationToken (Session Cookie)

This cookie is strictly necessary for the site to function correctly. It is used to protect you against cross site request forgery. It is removed when the browser is closed.

15.3.3 ai_user (Persistent Cookie)

This cookie is to determine if you have previously visited the site (within the past year). This cookie is created on first visit to the moneyinfo website and expires one year after created.

15.3.4 _ga (Persistent Analytics)

moneyinfo may set up Google Analytics on YourCAM. These cookies collect information about how you use the site. This information is collected anonymously and is used to understand how users are engaging with the service. This cookie expires after two years.

 

16. Your data protection rights

You have rights under data protection laws in relation to your personal information. This includes the following rights:

  • Right of access (commonly known as a ‘data subject access request’). This enables you to receive a copy of the personal information CAM and moneyinfo hold about you and to check that we are lawfully processing it.

  • Right to rectification. This enables you to have any incomplete or inaccurate information CAM and moneyinfo hold about you corrected.

  • Right to erasure. This enables you to ask CAM or moneyinfo to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

  • Right to object to processing. As CAM and moneyinfo have your consent to process your information you do not have the right to object to processing, but you do have the right to withdraw consent, which in effect acts as a right to stop the processing of your data.

  • Right to restriction of processing. This enables you to ask CAM or moneyinfo to suspend the processing of personal information about you, for example if you want us to prove its accuracy or the reason for processing it.

If you wish to exercise any of the rights set out above, please email clientservices@city-asset.co.uk.  You may also contact support@moneyinfo.com. moneyinfo ltd may need to request specific information from you to help us confirm your identity. This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. moneyinfo may also contact you to ask you for further information in relation to your request.

Right to data portability. This enables you to request the transfer of your information to another party. You can exercise this right within moneyinfo via the My Downloads area under the ‘Me’ menu. Here you can request a download of your moneyinfo data in a machine-readable format.

You are not required to pay any charge for exercising your rights. CAM and moneyinfo have one month to respond to you.