Manalo Advisors Ltd is committed to protecting your privacy and we recognise that we have a duty of care to the people within our data set. We will never spam you, or sell, rent or otherwise distribute or make public your personal information.
By using our website and services you consent to our collection and use of your Information as described in this Policy. If we change our Policy and/or procedures, we will update this Policy to keep you aware of what Information we collect, how we use it and under what circumstances we may disclose it. Your continued use of the website or services after this Policy has been amended shall be deemed to be your continued acceptance of the terms and conditions of this Policy, as amended. We encourage you to bookmark this Web page and review this Policy regularly.
1. Relevant Legislation
Along with Manalo Advisors Ltd’s business and internal computer systems, this website is designed to comply with the following national and international legislation with regards to data protection and user privacy:
Manalo Advisors Ltd’s website compliance with the above legislation, all of which are stringent in nature, means that this site is likely compliant with the data protection and user privacy legislation set out by many other countries and territories as well. If you are unsure about whether this site is compliant with your own country of residences’ specific data protection and user privacy legislation you should contact our Data Protection Officer for clarification.
2. Personal Information this Website Collects and Why We Collect it.
2.1 Information You Give Us
You may give us information about you by filling in forms on our site or by corresponding with us by phone, email or otherwise and we will only use that information as we specifically state when you provide that information or as set out in this Policy. If you are under 16 years of age you MUST obtain parental consent before filling in any forms on this website.
Some examples of the information that we collect and how we use it are:
2.2 Information We Collect About You
We may automatically collect technical information about each of your visits to our website.
Like most websites, Manalo Advisors Ltd’s website uses Google Analytics (GA) to track user interaction. We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to see their journey through the website.
Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. GA also records your computer’s IP address which could be used to personally identify you, but Google do not grant us access to this. We consider Google to be a third-party data processor (see section 6 below).
3. How We Store Your Personal Information
Manalo Advisors Ltd uses a third-party service called Heroku that allows us to collect data entered manually by visitors to our website who sign up for our Report Alerts. We do not keep information longer than we deem necessary. Information is stored on the website in a non-identifiable fashion and is wiped manually at the end of every month. This is currently the only occasion where personal data will be stored on this website. The email address that you submit will not be stored within any of our internal computer systems. For more information, please see Heroku’s privacy notice.
With regard to filling out the contact form on our website, we will only use the information you provide to respond to your query or suggestion. We do not keep information longer than we deem necessary.
4. Request a Copy of the Information We Hold About You
Under the Act you have the right to request a copy of the Information that we hold about you. This is known as a Subject Access Request. To process this request, we will require two pieces of identification to prove your identity. Please make a written application to the Data Protection Officer, Manalo Advisors Ltd, 19 Heathmans Road, London SW6 4TJ. We will respond within 30 days of the receipt of your request.
If any of the Information that we hold about you is incorrect and you’d like it amended, please contact the Data Protection Officer who will review your request.
Please note that:
Even if you delete Information, we may retain your Information in conformance with our data retention policy most specifically for legal and tax reasons and to honour your opt-out requests; and
We are not responsible for updating or removing your Information contained in the lists or databases of third parties who have previously been provided with Information as permitted by this Policy.
When you visit this website, we use session/transient cookies - these cookies only last for the duration of your browsing session and will normally be deleted by your browser when you close it. Session cookies do not collect information from the user’s computer.
6. About this Website’s Server
This website is hosted by Heroku. Full details of Heroku’s data security can be found here. All traffic (transferral of files) between this website and your browser is encrypted and delivered over HTTPS.
7. Our Third-Party Data Processors
We use a number of third parties to process personal data on our behalf. These third parties have been carefully chosen and all of them comply with the legislation set out in section 1. All 3 of these third parties are based in the USA and are EU-U.S. Privacy Shield compliant.
8. Data Breaches
We will report any unlawful data breach of this website’s database or the database(s) of any of our third-party data processors to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.
9. Data Controller
The data controller of this website is: Manalo Advisors Ltd, Company number OC403660. Registered Office: 19 Heathmans Road, London SW6 4TJ.
10. Data Protection Officer
Mr. Roderick Manalo
CEO, Manalo Advisors Ltd
Telephone: +44 (0)20 8220 9134