If you do not understand anything contained within this Privacy Policy or you have any questions, please contact us. Our contact information is as follows:

Head Office:
World Trade Centre,
1st Floor,
6 Bayside Road,
Gibraltar.
GX11 1AA

UK Office:
Metcalf Way,
Crawley,
West Sussex.
RH11 7XX

Telephone: +44 (0) 203 745 0294
Email: info@westbrookeassociates.com

This Privacy Policy explains in detail the types of personal data that Westbrooke Associates Limited, (“we” or “us” or “our”) we may collect from you when you interact with us or visit our website at https://westbrookeassociates.com. It also explains how we store and handle your data and how we protect it. We’ve included considerable information on this Privacy Policy, as we think it’s important that you’re fully aware of your rights. This includes how Westbrooke Associates Limited uses your data.

It’s likely that we’ll occasionally need to update this Privacy Policy. We’ll notify you about any significant changes, but you’re welcome to come back and refer to it regularly.

Explaining the legal base that we rely on
The law on data protection sets out several different reasons why a company may collect and process your personal data, including:

Consent
In specific situations, we can collect and process your data with your consent.
For example, when you send us a request or enquiry using the contact forms on our website.
We’ll always make it clear to you which personal data we’re collecting in relation to a particular service.

Legal compliance
We may need to collect and process your data if the law requires us to do so.

For example, forwarding personal data to a regulator, law enforcement body, legitimate government body such as HM Revenue & Customs or an arbitration panel in regards to investigations of fraudulent or criminal activity.

In the scenario that we intend to enter into a major corporate transaction, such as a sale of control of our or another business, we may divulge certain aspects of your personal data to potential buyers, underwriters or advisors.

We may on occasion, expand, reduce or sell our business, and this may mean the transfer of certain divisions or the whole business to other parties. Your personal data will, where it matters to any division so transferred, be transferred along with that division and the new owner or newly controlling party will, under the terms of this Privacy Policy, be allowed to use your personal data for the purposes for which it was given by you.

Legitimate interest
In specific situations, we require your data to pursue our legitimate interests in a way that might reasonably be expected and as a part of running our business. This doesn’t materially impact your rights, freedom, or interests.

For example, if we’ve identified a potential product or service, we may contact you to advise you of any developments that are likely to benefit you.

When do we collect your personal data?

• Whenever you visit our website.

• When you use the contact form or registration process on our website.

• If you email us, write to us or telephone us.

• Whenever you instruct us to complete work on your behalf.

• If you decide to invest via our services.

What sort of personal data do we collect?

• Your name, address and contact details.

• Details of your enquiry.

• Details of your interactions with us through telephone, email or in writing.

• Information gathered by the use of cookies in your web browser.

• Your bank account details.

• Your date of birth.

• A copy of proof of identity, such as passport or similar document,

• information about investments you have purchased through us, such as the amount invested, the product your purchased, etc.

If you are acting on behalf of a company, we might also collect:

• Certificate of Incorporation.

• Memorandum and Articles of Association.

• Copy of proof of identity (such as passport or similar document) for its shareholders and directors.

• Managerial and administrative contact information (emails and phone numbers).

How we use your personal data
We want to give you the best possible user experience. One way to achieve this is by understanding exactly who you are and combining this with the data we hold about you.

The data privacy law allows this as part of our legitimate interest in understanding our users and providing you with the highest levels of service.

Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide you with some of the services that you’ve asked for.

For example, if you ask us to delete your records prior to the completion of your investment purchase, this will prevent us from reaching a satisfactory outcome.

We may also use your personal data to confirm your identity and make sure that you qualify to use the investment services that we provide, according to relevant legislation, as well as other compliance responsibilities.

To carry out our obligations under our contracts with you or others, we may use your personal data for processing and administering any payments and investments that are connected with the services we offer, to facilitate investment transactions and for the creation of and maintenance of client registers and investments.

Data processing in connection with Google Analytics
This website uses Google Analytics, a web analytics service provided by Google Ireland Limited. If the responsible body for the data processing that occurs via this website has their basis outside of the European Economic area and Switzerland, then the associated Google Analytics data processing is carried out by Google LLC. Google Ireland Limited and Google LLC. will hereinafter be referred to as “Google”.

Google Analytics uses “cookies”, which are text files saved on the site visitor’s computer, to help the website analyse their use of the site. The information generated by the cookie (including the truncated IP address) about the use of the website will normally be transmitted to and stored by Google.

Google Analytics is used exclusively with the extension “_anonymizeIp ()” on this website. This extension ensures an anonymization of the IP address by truncation and excludes a direct personal reference. Via this extension Google truncates the site visitor’s IP address within member states of the European Union or other parties to the Agreement on the European Economic Area. Only in exceptional situations will the site visitor’s full IP address be transmitted to Google servers in the United States and truncated there. The IP address, that is provided by the site visitor’s browser in using Google Analytics will not be merged by Google with other data from Google.

On behalf of the site operator, Google will use the information collected to evaluate the use of the website, to compile reports on website activity and to provide other website and internet related services to the site operator (Art. 6 (1)( f) GDPR). The legitimate interest in data processing lies in the optimization of this website, the analysis of the use of the website and the adaptation of the content. The interests of the users are adequately protected by the pseudonymization of their data.

Google LLC. offers a guarantee to maintain an adequate level of data protection on the basis of European standard contractual clauses. The data sent and linked to the Google Analytics cookies, e.g. user IDs or advertising IDs will be automatically deleted after 50 months. The deletion of data whose retention period has been reached is carried out automatically once a month.

The website visitor may refuse the use of cookies by selecting the appropriate settings in their browser. The website visitor can also prevent Google from collecting information (including their IP address) via cookies and processing this information by downloading this browser plugin and installing it: http://tools.google.com/dlpage/gaoptout

The website visitor can prevent data collection via Google Analytics on this website by clicking here. An “Opt-out Cookie” shall then be applied which shall prevent any future collection of the site visitor’s data when visiting this website.

Further information concerning data processing and use by Google, the settings and deactivation possibilities can be found in the Google Privacy Policy (https://policies.google.com/privacy) as well as in the Google Ads Settings (https://adssettings.google.com/authenticated).

reCAPTCHA
We use the reCAPTCHA service provided by Google LLC (Google) to protect your submissions via internet submission forms on this site. This plugin checks if you are a person in order to prevent certain website functions from being (ab)used by spam bots (particularly comments). This plugin query includes the sending of the IP address and possibly other data required by Google for the Google reCAPTCHA service.

For this purpose, your input will be communicated to and used by Google. However, your IP address is previously truncated by Google within member states of the European Union or in other states which are party to the agreement on the European Economic Area and is, as such, anonymized. Only in exceptional cases is a full IP address transmitted to a Google server in the United States and truncated there.

On behalf of the operator of this website, Google will use this information to evaluate your use of this service. The IP address provided by reCaptcha from your browser shall not be merged with any other data from Google. This data collection is subject to the data protection regulations of Google (Google Inc.). For more information about Google’s privacy policy, please visit: https://policies.google.com/privacy?hl=en

By using the reCAPTCHA service, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

Social Media
We maintain publicly accessible profiles on various social media platforms such as Facebook, Instagram, Twitter and YouTube. Link these to the appropriate pages and platforms.

Above and beyond the processing of personal data specified here, we do not have any influence on the processing of personal data in connection with your use of our social media pages. This applies, in particular, to the use of interactive features, such as “comment”, “share” and “like”.

Dependent on the platform provider, it may be that other processes are performed by social media platform operators. For details, please refer to the terms of use and privacy policies of the respective social media platforms.

Data sharing
From time to time we outsource certain business functions, such as website maintenance services and specialist IT providers. All our outsourced providers are professionals in their fields and have strict data processing procedures and non-disclosure agreements in place.

Data retention
Once an enquiry or purchase is concluded and following the end of our working relationship, we retain your records for a period of no longer than five years. We do this in case your information is required for any reason, following completion of your purchase or enquiry.

During the time that we hold your records, we may contact you under a ‘legitimate interest’ basis if new developments occur that are likely to affect you. Particularly if the information we are providing to you will be of benefit.

How we protect and store your personal data
We know how much data security matters to all our customers. With this in mind, we treat your data with the utmost care and take all appropriate steps to protect it.

We securely store your digital data using cloud systems. We retain your data for a maximum period of five years following the end of our working relationship and or the satisfactory conclusion of your enquiry. We do this in case your information is required for any reason, following the completion of your enquiry or purchase.

Once this time period has expired, we permanently delete your digital data from our cloud storage systems, including overwriting any backup storage. We often seek specialist IT advice regarding secure document deletion, when required.

What are your rights over your personal data?
Here’s an overview of your different rights. You have the right to request:

• Access to the personal data we hold about you, free of charge in most cases.

• The correction of your personal data when it’s incorrect, out of date or incomplete.

• That we stop using your personal data.

• That we stop any consent-based processing of your personal data after you withdraw that consent.

• You can contact us to request to exercise these rights at any time.

If we choose not to action your request, we’ll explain the reasons for our refusal.

Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw your consent. This can be withdrawn by simply contacting us and letting us know.

Where we rely on our legitimate interest
In cases where we are processing your personal data on the basis of our legitimate interests, you can ask us to stop for reasons connected to your individual situation. We’ll adhere to this unless there is an alternative legal basis for us to continue processing your personal data, such as under contract.

Direct marketing
You have the right to discontinue the use of your personal data for direct marketing activity through all channels, or selected channels. We will always comply with your request. Simply contact us to opt-out or amend your marketing preferences.

Any questions?
We hope this Privacy Policy has been helpful in setting out the way we handle your personal data and your rights to control it.

If you have any questions, our contact options are detailed below:

• Telephone us: +44 (0) 203 745 0294

• Email us: info@westbrookeassociates.com