This Data Protection Framework has been designed to display our compliance with the European Union's General Data Protection Regulation (GDPR) and investment regulation compliance.
Markets Recon provides institutional investors and investment professionals with access to thought leadership and investment research. By providing this service, we will be capturing personal data by way of a registration process in order to create a user account and profile. This information may be used within the institutional investment industry as a form of ‘lead generation.’
In order to do this, we have strict compliance and data protection obligations as well as global regulatory requirements to adhere to.
As a limited liability company incorporated within the United Kingdom, we will comply with the Data Protection Act 2018 (as amended), which deeply complements the European Union’s GDPR, as well as investment compliance regulatory bodies such as (but not limited to) the United Kingdom’s Financial Conduct Authority (FCA).
Below is an extract from the GDPR directive which governs Markets Recon’s lawful access to personal data:
- Markets Recon’s lawful basis for the collection, processing, and sharing of personal data; and
- A party contracted with Markets Recon may have a lawful basis for communicating with, and receiving information relating to, any ‘leads’ produced by Markets Recon.
Markets Recon, during the business course of its dealings, will ‘anonymise, collect, distribute, engage, process, refer, and/or terminate’, personal data. What information is captured, and how this information is handled, has been illustrated below:
Markets Recon’s Personal Data Process
In order to provide an appropriate level of personalisation as well as adhering to regulatory compliance, Markets Recon gathers specific information from two groups - Potential users and existing users.
- Potential Users (marketing prospects)
Any non-existing user is, in other words, a marketing prospect for Markets Recon. Information may be gathered by research, or by interaction with the platform, in order for us, or a third party, to potentially engage a non-existing user in the future.
All users will provide, at the time of registering, personal information such as (but is not limited to) your: first name, last name, job title, professional email, employer’s name, and current domicile. Additionally, we’ll also ask you to select from a range of topics in order for us to personalise the Site for your benefit.
We may also collect information via the LinkedIn authentication process. When providing this information, you will have consented for us to collect this information and use it for the purposes we have explained previously.
Using the LinkedIn authentication process will allow a user to connect and create an account by using their LinkedIn information and credentials. This may give Markets Recon more information about a user, such as (but not limited to): employment sector, employment function, employment history, educational history, photos, website links and previous posts (published, shared, interacted with or created by the user), or any other information as made available on a users LinkedIn account.
Any amendments to the LinkedIn profile or the user's account post-registering may also be recorded.
As with marketing prospects, the same information may be collected during the same registration or post-registration process. Markets Recon may further collect information such as a user's current IP address, browser version, or any information that has been provided during any point or session when interacting with the platform.
By registering to use the Site, none of the information collected by Markets Recon is considered ‘sensitive personal data’ under GDPR, and as such, may be continued to be collected.
Markets Recon’s Data Collection
Data collected by Markets Recon on users serves a variety of purposes, such as:
All data relating to a marketing prospect is processed for the purpose of sending targeted marketing emails to those who may be interested in the Markets Recon platform.
It is within the scope of the current regulations to provide protections for both Markets Recon and a user in the course of collecting and processing personal information. Markets Recon collects information that may or may not need to be verified, or audited, in order to keep the integrity of the Site, and the business reputation of Markets Recon.
Any information which is deemed necessary to be shared will be restricted to information relating to the registration information supplied by a user during the registration process as well as any activity captured by a user during their use of the Site.
The information shared may consist of: title of the content viewed by a user, the date and time of the user’s interaction with the content, the country a user selected during the registration process, the current IP location of the user at the point content was accessed, their employer’s name (if applicable), a user’s job title, and their professional email address.
To provide a tailored service to a user, Markets Recon is required to collect personal information to the benefit of creating a purely customised user experience and for the business to operate.
Markets Recon’s Lawful Basis
Markets Recon makes every effort to keep up-to-date with the latest GDPR directive for users so they don’t have to. When it comes to data protection and processing, we strictly operate on a lawful basis. By this, we mean that all users of the Site provide their information by consent - Which we use to allow us to process a user's information.
All users agree to our Terms of Service, Privacy Policy, and Cookie Policy. Registration to the Site cannot proceed without this.
Whilst the Terms of Service and Privacy Policy outline the principles of how we process a user’s data, it is also the framework for other forms of data collection and processing.
If any other personal information is collected and processed, in particular, when it comes to marketing prospects and/or third parties, we process any collected information on the basis of ‘legitimate interests’ as governed by the GDPR directive.
Once any data has been collected and processed, it may also be shared. A user's information is only shared with their consent (which is provided upon registration as well as at the point of interacting with any information found within our platform).
The regulations which govern our method in which we obtain consent for sharing personal information from a user [about a user] is by taking a ‘just-in-time’ approach. This practice is the principle framework which is supported by the United Kingdom’s Information Commissioner’s Office.
The following process is one we adhere to with great effort:
Markets Recon’s Privacy Policy has been constructed with regards to the sharing of personal information in a simplistic, generic manner. All personal information which is shared will be based on the ‘just-in-time’ principle which will take effect as soon as a user of the Site engages with a piece of information.
Notification in the form of a disclaimer will be present at the point of interaction and a user who proceeds beyond this point will be deemed to have given consent. The disclaimer will contain within it wording which informs a user that their personal information may be shared with the owner of the content which is being interacted with; the disclaimer will also contain an acknowledgement and acceptance that the personal information may be shared with the expectation that communication from the data-receiving party may ensue.
By proceeding with the action to view any information on our platform, this will be deemed as ‘affirmative action.' The disclaimer is constructed in order to comply with the GDPR directive, in being clear and unambiguous.
Information
If anything is unclear, or you simply wish to discuss any elements of this document or GDPR further, please contact info@marketsrecon.com.
Markets Recon’s Disclaimer
At no point does Markets Recon constitute, in itself, compliance with all applicable regulations. All information and material supplied by a user must be constructed in accordance and with compliance to the applicable regulations applying to each user in their own jurisdiction.
Each user should seek legal counsel to ensure compliance with the relevant regulations which govern their actions on our platform.
No information presented in this document or anywhere on the Site is deemed to represent legal or compliance advice.
