PRIVACY AND COOKIES POLICY

INTRODUCTION

Tempo Structured Products (‘Tempo’) is committed to protecting and respecting your privacy when you are using our website our social media pages or communicating electronically with us.

This Privacy and Cookies Policy is part of our website Terms and Conditions and should be read in conjunction with the website Terms and Conditions.

This policy (together with our website Terms and Conditions) explains what type of information and data we may collect when you use our website and the basis on which any personal information and data that we collect from you, or that you provide to us, will be processed by us.

Please read the policy carefully so that you understand our practices regarding your personal information and data and how we will treat it. By disclosing your personal information to us when using our website you consent to the collection, storage and processing of your personal information and data as detailed in this Policy.

DATA CONTROLLER

For the purpose of the Data Protection Act 1998 (the “Act”), the data controller is ARC SP LLP (trading as Tempo Structured Products), which is registered with the ICO with registered number ZA336971.

WHO WE ARE AND THE GROUP THAT WE ARE PART OF

Tempo Structured Products is a trading name of ARC SP LLP, registered in England under number OC400846, with its registered offices at 338 Euston Road, London NW1 3BG. Tempo Structured Products is an appointed representative of TIME Investments, which is a trading name of Alpha Real Property Investment Advisers LLP. Alpha Real Property Investment Advisers LLP is authorised and regulated by the Financial Conduct Authority, 25 The North Colonnade, Canary Wharf, London E14 5HS, under FCA number 534723. Tempo Structured Products and TIME Investments are subsidiaries of Alpha Real Capital LLP group, which is authorised and regulated by the Financial Conduct Authority, under FCA number 436048.

WHAT PERSONAL INFORMATION AND DATA MIGHT WE COLLECT?

We may collect, store and use the following kinds of personal information:

• If you wish to register to access our Issuer & Counterparty Scorecards and / or our Professional Adviser Academy, you will be asked to provide your name, company name, telephone number and email address;
• If you wish to complete our Distributor Due Diligence you will be asked to provide some or all of the information requested in the questionnaire;
• If you wish to submit an enquiry, provide feedback or request contact or information from us, you will be asked to provide your contact details;
• We may also collect, store and use information about your computer, mobile device and / or other item of hardware through which you access our website and your visits to and use of our website, including, but not limited, to your: IP address; geographical location; browser / platform type and version; Internet Service Provider; operating system; referral source / exit pages; length of visits; page views; website navigation and search terms that you use;
• In order to improve your experience using our website, we may also store and analyse non-personalised browsing information relating to your use of our website.

WHY WE MAY COLLECT PERSONAL INFORMATION AND DATA AND HOW WE MIGHT USE PERSONAL INFORMATION AND DATA

We use the personal information and data we collect to provide our services to you and improve your experience in using our website, including, but not limited to:

• So that we can provide you with access to our Issuer & Counterparty Scorecards and Professional Adviser Academy;
• To undertake distributor due diligence on you and your firm;
• In order for our Plan Administrator to facilitate adviser fee payments to you / your firm;
• To provide you with details about our products and services, including information about product launches and offer periods and events.
• To deal with enquiries, feedback or complaints from you;
• To enable you to use our website and to help us manage, maintain and improve it and your browsing experience to better meet your and other user’s needs;
• To help address and resolve disputes, including complaints and to enforce our website Terms and Conditions.

WHEN MIGHT WE DISCLOSE PERSONAL INFORMATION AND DATA?

Except to the extent required by any applicable law or governmental or judicial body, we will not disclose your personal information or data to any third party outside of our group and suppliers involved in the provision of our services (such as our Plan Administrator).

Though we make every effort to preserve your privacy, we may need to disclose your personal information and data when required to do so by law or regulations, or if we have good-faith belief that such action is necessary to:

• Comply with a judicial proceeding, court order or legal process served on us or our website;
• Comply with any request by the FCA and / or the Prudential Regulation Authority in the UK (or any other regulator who may have jurisdiction over us);
• Enforce this Privacy and Cookies Policy or our website terms and conditions;
• Respond to claims that your personal data violates the rights of third parties; or
• Protect the rights, property or personal safety of Tempo Structured Products and the public;

By accepting our Privacy and Cookies Policy you consent to and authorise us to disclose any information about you to law enforcement or other government officials as we, in our sole discretion, believe may be necessary or appropriate, in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose us or you to legal liability.

We will not rent, sell or share your personal information with any other company outside of our group or any service supplier to us (such as our Plan Administrator) without your consent, except where this may be required, as explained in this Policy.

OUR USE OF COOKIES AND WEB BEACONS

Cookies are text files stored, either on a temporary or persistent basis on the hard drive of your computer. Cookies are used for authenticating, session tracking and maintaining specific information about the use and users of websites.

If you wish to use our website, you are required to accept the Terms and Conditions of use of our website. If you wish to access the current products area of our website, we also require you to accept the Terms and Conditions of use of our current products area. If you accept the Terms and Conditions of use for our website and / or our current products area we will use a cookie in order to register your acceptance of our Terms and Conditions. These cookies remain in place for 90 days.

The data collected by cookies is anonymous. You can delete all cookies that are already on your computer’s hard drive by searching for files with “cookie” in it and deleting them. If you delete your cookies, you will need to reaccept our Terms and Conditions in order to access our website and / or the current products area of our website. In addition, if you want to stop cookies from being stored on your computer, you can edit your browser settings so that cookies are blocked. If you block cookies, you will need to reaccept our Terms and Conditions in order to access our website and / or the current products area of our website.

Web beacons consist of a small string of software code that represents a graphic image request on a page or email. There may Or may not be a visible graphic image associated with the web beacon and often the image is designed to blend into the background of a page or email. Web beacons can be used for many purposes – including site traffic reporting, unique visitor counts, advertising auditing and reporting, and personalisation. Web beacons used by www.tempo-sp.com collect only anonymous data.

In order to improve our website and the services we offer you, we may use temporary and persistent cookies, authorised third parties cookies, web beacons and/or other technologies to collect non-personally identifiable data.

If you use our website, you agree to our use of cookies.

WHERE WE STORE YOUR PERSONAL DATA

We take the security of your personal data very seriously.

All information you provide to us is stored on our secure servers, which are located in the EEA.

Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

In particular, we use all reasonable endeavours to ensure that appropriate security measures are in place to protect your personal data.

Unfortunately, the transmission of information via the internet is not completely secure and so we cannot guarantee the security of your data transmitted through our website; any transmission is at your own risk.

LINKS TO THIRD PARTY WEBSITES

Our website may include links to third party websites. We are not responsible for the content of third party websites. Please ensure that prior to using any such website, you have read and understood its terms and conditions and privacy and cookies policy. These will govern your rights, and obligations, when using the website.

YOUR RIGHTS

You can exercise your right to request details of any information that we have collected and stored about you at any time by contacting us at info@tempo-sp.com.

CHANGES TO OUR PRIVACY AND COOKIES POLICY

We reserve the right to amend our Privacy and Cookies Policy.

Any changes we may make will be posted on this page and, where appropriate, notified to you by e-mail.

CONTACT

If you have any questions, comments and / or requests regarding our Privacy and Cookies Policy these should be addressed to info@tempo-sp.com.

INFORMATION COMMISSIONER’S OFFICE

For more information about data protection and the protection of personal information, please visit www.ico.org.uk.