Asanto Privacy Policy 2023

Last updated: December 2023

Who are we?

Investment Discounts On Line Limited trading as Asanto is part of the Legal & General Group and is the registered data controller of your personal data for the purposes of the Data Protection Act.

What is our Data Protection role?

Asanto is a data processor in a business-to-business environment and our subscribers are direct users of the Asanto platform. Our subscriber will be deemed the “data controller” (under Data Protection Legislation including General Data Protection Act 2018) of such Customer Data; and Asanto will be deemed the “data processor” when processing and storing such data. The Asanto platform processes Customer Data, and the personal data contained in it, on behalf of our subscribers, in accordance with their agreement.

What does this policy cover?

This privacy policy relates to users, both potential and existing subscribers who enter into agreements with us.

What is personal information?

When we talk about personal information or Customer Data, we mean information about an individual that can identify them, like their name, address, e-mail address, telephone number and financial details. It can relate to customers, employees, business contacts, subscribers, and suppliers. Any reference to “information” or “data” in this policy is a reference to personal information about a living individual.

What information do we hold?

We may collect and process the following types of information about our users.

Type of data	Description	Examples of how we use it
Personally Identifiable Information (contact details)	This is the personal information which you provide to us in order to use the Asanto service, including use of our 3rd party helpdesk (theidol.freshdesk.com) Who you are How to contact you Financial details	Provision of information requested Managing and servicing our business relationship Business to business marketing Finacial Crime prevention
Data Aggregation	We collect anonymised data, as agreed with subscribers, which does not contain any personally identifiable information.	Managing and servicing our business relationship Analysis and insight into end user behaviour
Other Information Asanto Collects	We automatically collect details about your visits to our website (Asanto.com) via cookies and other tracking technology.	Managing and servicing our business relationship Analysis and insight into end user behaviour
Contractual	Your creditworthiness (if applicable) Transactional payment details	Managing and servicing our business relationship
Preferences	Ways you want us to market to you	Business to business marketing
Open data & public records	Other information about you that is openly available on the internet (such as Companies House) Company details	Managing and servicing our business relationship

Where do we get our information from?

• Information you give us directly (when you fill in online forms, contact us by phone or e-mail or request information regarding our products and service). We may record phone calls for our mutual protection, to meet our contractual obligations and to improve our customer service standards.
• Information we collect about you or receive from other sources.

This could be information you provide to us electronically, information we get from a third party or from publicly available sources such as (Companies House). For more information on how we use cookies, please check our cookie policy which can be found on our website.

How do we use your information?

We use personal information that we hold about you:

• To create your subscriber account on our servers.
• To provide high level monitoring of visitors using our website.
• To carry out our joint responsibilities resulting from any business or commercial agreements you have entered / may be entering into with us and to provide you with the information, products, and service that you have asked from us.
• To tell you about changes to our products and service.
• To comply with any applicable legal requirements.
• For carrying out statistical analysis to help us improve our processes, products and service and generate new business.
• To run our business in an efficient and proper way, such as testing our systems, business capability, planning, communications, corporate governance, and audit.
• For system administration needs.
• For any other purpose that we have agreed with you from time to time.

Using your information in accordance with data protection laws

Data protection laws require us to meet certain conditions before we are allowed to use your personal information in the way we describe in this privacy policy. We take these responsibilities extremely seriously. To use your personal information, we will rely on the following conditions, depending on the activities we are carrying out:

• Providing our contracts & services to you: We will process your personal information to carry out our responsibilities resulting from any commercial agreements or contracts you have entered into with us and to provide you with the information, products, and service you have asked from us, which may include online services. This includes using your information to improve the quality of the products and service, and to notify you of any changes to your requests. This may include negotiations for entering into a contract with us.
• Complying with applicable laws: We may process your personal information to comply with any legal obligation we are subject to.

• Legitimate interests:To use your personal data for any purpose described in this privacy policy, we will rely on a condition known as “legitimate interests”. It is in our legitimate interests to collect your personal data as it provides us with the information that we need to provide our services to you more effectively

  We may use your information to:

  • Develop, test, and manage our products and service.
  • Study and manage how our professional business clients use products and services from us and our business partners.

This requires us to carry out an assessment of our interests in using your personal data against the interests you have as a citizen and the rights you have under data protection laws.

The outcome of this assessment will determine whether we can use your personal data in the ways described in this privacy policy. We will always act reasonably and give full and proper consideration to your interests in carrying out this assessment.

• Consent: We may process your personal information for different purposes where you have provided your consent to do so.
• Criminal Conviction Data: We may process this type of information solely for the purpose of preventing fraud.

Please be aware that the personal information you provide to us and which we collect about you, is required for us to be able to provide our services to you and without it we may not be able to do so.

How long do we keep your information for?

We will keep your personal information in accordance with our internal retention policies. We will determine the length of time we keep it for based on minimum retention periods, taking account of our business agreement, or as required by law. We will only keep your personal information after this period if there is a legitimate and provable business reason to do so.

Who do we share your personal information with?

We may disclose your information to:

• Other companies within Investment Discount Online Limited, third-party suppliers, and contractors for the purposes listed under “How do we use your information? ” above.
• Our government (e.g., HMRC) and law enforcement or fraud prevention agencies, and your regulators.

Additionally, we may disclose your personal information to third parties:

• If we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
• If we, or substantially all our assets, are acquired by a third party, in which case personal data held by us about our professional business clients will be one of the transferred assets.
• In order to enforce or apply the terms of any contract we have with you.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or regulatory requirements, or otherwise for the prevention or detection of fraud or crime.
• To protect all parties from financial crime, we may be required to verify the identity of new and sometimes existing professional business clients. This may be achieved by using reference agencies to search sources of information relating to you (an identity search). This will not affect your credit rating. If this fails, the business may need to approach you to obtain documentary evidence of identity.
• In accordance with business agreements, we may perform credit checks on professional business clients.

Fraud prevention

information is provided and fraud is identified details will be passed to fraud prevention agencies. Law enforcement agencies may access and use this information. We may also share information about you with other organisations and public bodies, including police and we may check and/ or file your details with fraud prevention agencies and databases.

Investment Discounts On Line Limited and other organisations may also access and use this information to prevent fraud and money laundering, for example, when:

• Managing credit and credit related accounts of facilities.
• Recovering debt.
• Checking details on professional business clients.

Investment Discounts On Line Limited and other organisations may access and use from other countries the information recorded by fraud prevention agencies. Please contact the Asanto team at support@asanto.com

Address: Investment Discounts On Line Limited, Eden Business Park, Penrith, Cumbria, CA11 9FB.

Transferring your data outside the EU

For subscribers within the European Economic Area (EEA) the data we collect from you will be transferred to, and stored by, third-party suppliers, at a destination within the European Economic Area (“EEA”). We will take all reasonably necessary steps to make sure that your data is treated securely and in accordance with this privacy policy.

Should we want to transfer or store data outside the EEA we will provide you with the details.

For subscribers located outside of the European Economic Area (EEA) the data we collect from you will be transferred to, and stored by, third-party suppliers, at a destination outside the European Economic Area (“EEA”). We will take all reasonably necessary steps to make sure that your data is treated securely and in accordance with this privacy policy.

Your rights

You have rights under data protection law that relate to the way we process your personal data. More information on these rights can be found on the Information Commissioner’s website. If you wish to exercise any of these rights, please get in touch with us by emailing support@asanto.com

1	The right to be informed about how we process your personal information This right is met by the provision of this document.
2	The right to access the personal date we hold about you.
3	The right to make us correct any inaccurate personal data we hold about you.
4	The right to make us erase any personal data we hold about you. This right will only apply where for example: We no longer need to use the personal data to achieve the purpose we collected it for You withdraw your consent if we are using your personal data based on that consent Where you object to the way we use your data, and there is no overriding legitimate interest
5	The right to restrict out processing of the personal data we hold about you. This right will only apply where for example: You dispute the accuracy of the personal data we hold You would like your data erased, but we require to hold it in order to stop its processing You have the right to require us to erase the personal data but would prefer that our processing is restricted instead Where we no longer need to use the personal data to achieve the purpose we collected it for, but you need the data for legal claims.
6	The right to object to our processing of personal data we hold about you (including for the purposes of sending marketing materials to you).
7	The right to receive personal data, which you have provided to us, in a structured, commonly used and machine-readable format. You also have the right to make us transfer this personal data to another organisation.
8	The right to withdraw your consent, where we’re relying on it to use your personal data.

Contacts and complaints

If you have any questions about this privacy policy or wish to exercise any of your rights, including changing your marketing preferences, please get in touch with us by emailing support@asanto.com.

If you have any concerns about the way we process your personal data or are not happy with the way we have handled a request by you in relation to your rights, you also have the right to make a complaint to the Information Commissioner's Office. T heir address is:

First Contact Team Information Commissioner's Office Wycliffe House Water Lane Wilmslow SK9 5AF

Data Protection Officer

If you would like to exercise your right to access any personal information that we hold about you, write to: theidol.com, The Edge, Eden Business Park, Penrith, Cumbria CA11 9FB.

You can also contact our Data Protection Manager directly with any questions or issues relating to the way we process your personal information:

Email address: datacontroller@theidol.com
Address: The Edge, Eden Business Park, Penrith, Cumbria, CA11 9FB

If you are not satisfied with the way we deal with your enquiry you can escalate your request to:

Group Protection Officer
Email address: data.protection@landg.com
Address: 1 Coleman Street, London, EC2R 5AA