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Our privacy policy.

How we protect your personal information and your privacy rights

Version 1.3

October 30, 2023

Privacy policy

Version 1.3

  1. Introduction
    1. TCA Digital Ltd (t/a "InsiderList" and "InsiderList.com") ("TCA") respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
    2. This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the glossary  to understand the meaning of some of the terms used in this privacy policy.
  2. Important information and who we are
    1. Purpose of this privacy policy
      1. This privacy policy aims to give you information on how TCA collects and processes your personal data through your use of this website, including any data you may provide through this website when you purchase a product or service.
      2. This website is not intended for minors. We do not knowingly collect personal information from children under the age of 13. If we become aware that we have inadvertently received personal information from a child under the age of 13, we will delete such information from our records.
      3. It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
    2. Controller / Processors
      1. For the purposes of General Data Protection Regulation ((EU) 2016/679) (EU GDPR), the UK retained law version of EU GDPR (UK GDPR), the UK Data Protection Act 2018 (UK DPA 2018), and the Jersey Data Protection (Jersey) Law 2018 (JE GDPR), where we are the party that determines the purposes and means of the processing of personal data, TCA Digital Ltd is the controller and responsible for your personal data.
      2. However, we may also collect or be provided with certain personal data pursuant to our agreements with our clients and partners, which we process on their behalf. In this case, we act as a processor of the relevant client or partner, who remains the controller.
      3. We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
    3. Contact details
      1. If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:
        1. Our UK Representative
          1. Under Article 27 of the UK Data Privacy Act, we have appointed a UK Representative to act as our data protection agent.
          2. Our nominated UK Representative is:
            Full name of legal entityGDPR Local Ltd
            Email addresscontact@gdprlocal.com
            Postal address1st Floor Suite, 27-29 North Street, Brighton, England, BN1 1EB
            Telephone+441772217800
        2. Our EU Representative
          1. Under Article 27 of the GDPR, we have appointed an EU Representative to act as our data protection agent. Our nominated EU Representative is :
            Full name of legal entityInstant EU GDPR Representative Ltd
            Email addresscontact@gdprlocal.com
            Postal addressOffice 2, 12A Lower Main Street, Lucan Co. Dublin, K78 X5P8, Ireland
            Telephone+35315549700
      2. You have the right to make a complaint at any time to the supervisory body for the relevant jurisdiction you live in. In the UK this is the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
    4. Changes to the privacy policy and your duty to inform us of changes
      1. We keep our privacy policy under regular review and reserve the right to amend the policy.
      2. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
  3. The data we collect about you
    1. Personal data we collect
      1. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
      2. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
        1. Identity Data includes your name.
        2. Contact Data includes your email address and telephone numbers.
        3. Financial Data includes bank account and payment details.
        4. Subscriber Data includes the name of the corporate subscriber authorised for access to our service, and your job title and description.
        5. Technical Data includes internet protocol (IP) addresses, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
        6. Profile Data includes your username and password.
        7. Usage Data includes information about how you use our website, products and services.
        8. Marketing and Communications Data  includes your preferences in receiving marketing from us and our third parties and your communication preferences.
      3. If you are a user of our services, we may be legally obligated under article 18 of the EU Market Abuse Regulation No 596/2014 (“MAR”) to collect and store personal data from you such as: (i) name and surname, (ii) personal identification number, (iii) surname by birth, (iv) private and work phone number, (v) position, and (vi) home address.
      4. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
      5. We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
    2. If you fail to provide personal data
      1. Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
  4. How is your personal data collected?
    1. We use different methods to collect data from and about you including through:
      1. Direct interactions. You, or your employer, may give us your Identity, Contact, and Profile Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
        1. apply for our products or services;
        2. create an account on our website;
        3. subscribe to our service or publications;
        4. give us feedback or contact us.
      2. Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy  for further details.
      3. Third parties or publicly available sources.  We will receive personal data about you from various third parties and public sources as set out below:
        1. Technical Data from the following parties:
          1. analytics providers based inside and outside the EU, the UK and Jersey;
          2. advertising networks based inside and outside the EU, the UK and Jersey; and
          3. search information providers based inside and outside the EU, the UK and Jersey.
        2. Identity, Contact and Corporate Subscriber Data from corporate subscribers to whom we are providing services
  5. How we use your personal data
    1. Framework
      1. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
        1. Where we need to allow you to access our products and services, our provide support services to you.
        2. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. For example, our legitimate interests may include the administration and management of our business and the provision of our services to the corporate subscriber authorising your access to our services.
        3. Where we need to comply with a legal or regulatory obligation.
      2. Clickhere  to find out more about the types of lawful basis that we will rely on to process your personal data.
      3. Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
    2. Purposes for which we will use your personal data
      1. We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
      2. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
        Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interest
        To register you as a new
        customer        		(a) Identity
        (b) Contact
        (c) Subscriber        		Performance of a contract with
        you
        To process and deliver your
        order including:
        (a) Manage payments, fees and
        charges
        (b) Collect and recover money
        owed to us        		(a) Identity
        (b) Contact
        (c) Subscriber
        (d) Financial
        (e) Transaction
        (f) Communications        		(a) Performance of a contract
        with you
        (b) Necessary for our
        legitimate interests (to recover debts due to us)
        To manage our relationship with
        you which will include:
        (a) Notifying you about changes
        to our terms or privacy policy
        (b) Asking you to leave a review
        or take a survey        		(a) Identity
        (b) Contact
        (c) Profile
        (d) Communications        		(a) Performance of a contract
        with you
        (b) Necessary to comply with a
          legal obligation
        (c) Necessary for our
        legitimate interests (to keep our records updated and to study how customers
        use our products/services)
        To administer and protect our
        business and this website (including troubleshooting, data analysis, testing,
        system maintenance, support, reporting and hosting of data)        		(a) Identity
        (b) Contact
        (c) Technical
        (d) Subscriber        		(a) Necessary for our
        legitimate interests (for running our business, provision of administration
        and IT services, network security, to prevent fraud and in the context of a
          business reorganisation or group restructuring exercise)
        (b) Necessary to comply with a
          legal obligation
        To deliver relevant website
        content to you and measure or understand the effectiveness of the services we
        provide to you        		(a) Identity
        (b) Contact
        (c) Profile
        (d) Usage
        (e) Communications
        (f) Technical
        (g) Subscriber        		Necessary for our legitimate
        interests (to study how customers use our products/services, to develop them,
        to grow our business and to inform
        our marketing strategy)
        To use data analytics to
        improve our website, products/services, marketing, customer relationships and
        experiences        		(a) Technical
        (b) Usage
        (c) Subscriber        		Necessary for our legitimate
        interests (to define types of customers for our products and services, to
        keep our website updated and relevant, to develop our business and to inform
        our marketing strategy)
        To make suggestions and
        recommendations to you about goods or services that may be of interest to you        		(a) Identity
        (b) Contact
        (c) Technical
        (d) Usage
        (e) Profile
        (f) Communications
        (g) Subscriber        		Necessary for our legitimate
        interests (to develop our products/services and grow our business)
      3. Cookies
        1. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.
      4. Change of purpose
        1. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
        2. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
        3. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
  6. Disclosures of your personal data
    1. We may share your personal data with the parties set out below for the purposes set out in the table above.
      1. Internal Third Parties as set out in the   glossary.
      2. External Third Parties as set out in the   glossary.
      3. Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
    2. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
  7. International transfers
    1. We store and process your personal data on servers located within Jersey, the UK and the European Union (the “EU”).
    2. Whenever we transfer your personal data out of the EU, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
      1. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data, such as the UK and US.
      2. Where we use certain service providers, we may use specific contracts approved which give personal data the same protection it has in the EU.
    3. We may transfer the personal information we collect about you to recipients in countries other than the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to recipients in other countries (such as the U.S.), we will protect that information as described in this Privacy Policy and will comply with applicable legal requirements providing adequate protection for the transfer of personal information to recipients in countries other than the one in which you provided the information, including by selecting service providers that are located in a country recognized by the European Commission as providing an adequate level of data protection or by implementing appropriate safeguards based on the European Commission’s Standard Contractual Clauses, where applicable. Subject to applicable law, you may obtain a copy of these safeguards by contacting us as indicated below.
  8. Data security
    1. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
    2. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
    3. TCA employs encryption technology to protect certain transmissions of data to/from the Services, but e-mail and other communications are not encrypted. By employing e-mail or other insecure electronic communication means you acknowledge that you have no expectation of privacy with respect to the information delivered and that TCA will not be responsible for any loss or damage that could result from interception by third parties of any information so sent.
  9. Data retention
    1. How long will you use my personal data for?
      1. We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
      2. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
      3. By law we have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for six years after they cease being clients.
      4. In some circumstances you can ask us to delete your data: see your legal rights  below for further information.
      5. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
  10. Glossary
    1. External third parties means:
      1. Service providers acting as processors based in Jersey, the UK, the EU and the USA, who provide IT and system administration services.
      2. Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in Jersey, the UK and the EU who provide consultancy, banking, legal, insurance and accounting services.
      3. Regulators and other authorities acting as processors or joint controllers based in Jersey, the UK and the EU who require reporting of processing activities in certain circumstances.
    2. Internal third parties means other companies in our Group (acting as joint controllers or processors) and who are based in Jersey and provide IT and system administration services and undertake leadership reporting.
    3. Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
    4. Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

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