Goal Group – Privacy Statement
This statement explains what we do with people’s personal data, and how people can exercise their rights over it.
Who we are and how to contact us
We are Goal Group Limited. We are an English company with company number 2438530, and our registered office is 9 Perseverance Works, Kingsland Road, London E2 8DD.
This statement is intended to provide a succinct, easily understood overview of what we do with people’s personal data. If you have any questions or concerns about the information in this statement, or about our handling of personal data more generally, or if you would like more detailed information, you should email us at email@example.com or write to us at the above address for the attention of the Audit, Data Protection & Diversity Officer.
A note about what we do for our clients, and our role in that work
We are predominantly a service provider to investment managers, financial institutions and similar businesses, who engage us to manage claims which they make on behalf of their clients in connection with withholding tax reclaims and securities class actions recoveries.
Typically, those businesses will pass to us the name and address of their client, and the details of the underlying securities transactions, dividends etc. to facilitate our work.
In that role, we are what the law terms the “data processor” of that personal data. That means that the investment manager, financial institution or other entity which is our client tells us what they want us to do with the data, and we do that on their behalf. They remain ultimately in charge of, and responsible for, that data. We do not do anything else with it.
It follows that, if you are a client of an investment manager, financial institution or similar business that we provide our services to, you should contact them for more information or to exercise your rights.
Occasionally, we do act directly for the beneficiary of a security or tax reclaim. In those instances, we do act as the data controller.
The rest of this statement explains what we do with personal data where we are the data controller.
The data we collect, what we do with it and why
If we are acting directly for you as an individual who is the beneficiary of a security class action recovery or tax reclaim, then we will collect from you information about your tax claim and/or the securities you hold, as well as your name, address and email address. We use that information to carry out our agreement with you to pursue your claim on your behalf, to administer our accounts and bill you for our services, and to provide you with access to our client portal so you can monitor progress of your claim.
Otherwise, we collect:
- Business contact details of the people we interact with at our existing clients, so we can provide our services, communicate with them, manage our relationship with them, and promote our services to them.
- Business contact details of the people we interact with at our suppliers and other businesses we communicate with in the course of our operations, so we can manage our relationships with them and run our business.
- Business contact details of people at prospective clients, in order to promote our services to them and discuss matters such as commercial and contractual arrangements with them prior to becoming a client. We will always stop contacting someone for promotional purposes if they ask us to, although it may take up to 10 days to remove people from email marketing lists and other databases.
Who we share that data with
We safeguard the rights of the relevant data subjects, to the extent that European or UK data protection law applies to them, by means of contractual arrangements with our subsidiaries in the forms mandated by the EU Commission. Affected people can request copies of those arrangements by email to firstname.lastname@example.org.
Otherwise, we only share the data we collect as data controller with:
- our subsidiary companies, as necessary for the purposes we collected it for; and
- our suppliers, to the extent necessary for them to perform their services to us.
How long do we keep it for?
We keep the personal data of individual beneficiaries and claimants that we act for, and the business contact details of personnel at our corporate clients, suppliers and the other businesses we interact with, for the duration of our relationship with them, and for 10 years afterwards.
We keep business contact details of people at prospective clients for as long as we are actively engaged in discussions with them, and for 10 years afterwards.
The legal basis on which we process it
If we are acting directly for you as a private individual who is the beneficiary of a security class action recovery or tax reclaim, then we process your personal data on the basis that it is necessary in order to carry out our agreement with you to pursue your claim.
- We process the business contact details of people at our clients, our suppliers and the other businesses we interact with on the basis of our legitimate interest in interacting with those businesses to provide our services to them, procure goods or services from them and otherwise to operate and to carry out our functions as an investment claims and tax reclamation business.
- We process the business contact details of people at prospective clients on the basis of our legitimate interest in promoting and arranging to provide our services to new clients.
Your rights and how to exercise them
In respect of data where we are the data controller, the law gives you certain rights in respect of the information that we hold about you. Below is a short overview of the most commonly-used rights. It is not a complete, exhaustive statement of your rights in respect of your personal data. The website of the Information Commissioner’s Office has a wealth of useful information in respect of your rights over your personal data.
If you wish to exercise your rights, the best way to do so is by email to email@example.com, but if you prefer you can also write to us at the address above.
Your right to a copy of the information we hold about you
With some exceptions designed to protect the rights of others, you have the right to a copy of the personal data that we hold about you, as well as information about what we do with it, who we share it with and how long we will hold it for. We may make a reasonable charge for additional copies of that data beyond the first copy, based on our administrative costs.
Your right to have inaccurate information about you corrected
You have the right to have the information we hold about you corrected if it is factually inaccurate. In most cases the easiest way to do that is to ask your usual contact with us to arrange that.
Your right to object to what we do with your data, and to have restrictions placed upon it
Where we process your personal data on the basis of our legitimate interest, you have the right to object to that processing and to have restrictions placed upon it while we consider your objection.
Your right to have your information deleted in some circumstances
You have the right to require us to delete the information that we hold about you if it is no longer necessary for the purpose we collected it for, and there is no other legal basis on which we must, or are allowed to, retain it.
Your right to complain to the ICO
You have the right to lodge a complaint about our handling of your personal data with the supervisory authority, which in the UK is the Information Commissioner’s Office.
You can contact the Information Commissioner’s Office on 0303 123 1113.