Homegrown Group Limited (“Homegrown” / “we”) collects information from our users and potential users at several different points on www.homegrown.co.uk (the “Website”) as well as through email, postal and telephone correspondence, face-to-face meetings and through replies to questionnaires.
By continuing to access the Website, by providing information by email, post, phone, in person or through any other medium, or by registering to use the Website as a Registered User, you are accepting and consenting to Homegrown’s use of your personal data in the ways set out in these policies.
The following personal data relating to you may be collected:
Information you provide. You may provide information to us through web forms on the Website, livechat, email, letter, phone, face-to-face meetings, customer surveys or through third parties that we work with, including payment and custodian service providers, KYC service providers or any individual or company that introduces you to Homegrown.
The information you provide may include your name, prefix, address, e-mail address, phone number, date of birth, username, password (encrypted), information contained on ID documents (including passport, driving license and national ID cards), bank statements, proof of address, details about your academic qualifications and historic investment experience, investor self-certification, details of financial transactions and investments made with Homegrown, questionnaire answers and your general communications with us.
We will not intentionally or systematically seek to collect, store, use or otherwise process information about you classed as ‘sensitive personal data’ (for example, information relating to any trade union membership, ethnic origin or medical conditions). We cannot prevent you from disclosing the same to Homegrown, or Homegrown’s agents, as part of your correspondence with us but you should ensure that such information is only provided where it is absolutely necessary.
Information we collect. We automatically collect certain information to help analyse the Website and our service, including; Technical information like the Internet Protocol (IP) address used to connect your computer or device to the internet, your browser type and version, time zone setting, operating system and platform; and Information about your visit including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); pages you visited or searched for; page response times, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our contact numbers.
Information on the cookies that we use to assist us in gathering such information can be found in our Cookies Policy.
Homegrown will only use your personal information where necessary and where we have a lawful reason to do so, including; to comply with a legal or regulatory obligation; where we have a legitimate interest (it is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect your personal data which overrides those legitimate interests); or where you have provided consent.
Homegrown uses the information you provide in order to contact you to request further information, to provide you with information, or inform you about changes, or to provide our product or service. We may keep information on file to help us to assess how effective our various marketing programs are, and to comply with regulations that our regulator (the Financial Conduct Authority) may from time to time impose on us.
Homegrown uses the information we collect to ensure our Website and other communications with you are presented in the most effective way, to administer and improve the Website (including troubleshooting it and carrying out testing and analysis), to ensure that our Website and other arrangements for collecting your data and communicating with you are as secure as possible and for marketing purposes.
Homegrown might share your information with others, in limited circumstances, including as follows:
We will share your information amongst Homegrown’s group companies (that means companies that partially own Homegrown or are owned by Homegrown) – as they may help in analysing and progressing your potential instructions.
We work closely with selected third parties who may support Homegrown in providing its product and service, marketing and contacting you who may assist in collecting and storing your information, including payment and custodian service providers, KYC service providers, IT service providers and marketing/communication service providers.
We may share information with analytics and search engine providers that assist us in the improvement and optimisation of our site.
We may need to disclose your information if required by law, if we believe that disclosure is necessary to comply with a current judicial proceeding, or a court order or legal process served on us. In the event Homegrown goes through a business transition, such as a merger, being acquired by another company, or selling a portion of its assets, users’ your information will, in most instances, be part of the assets transferred.
We use a data hosting service provider located within the European Economic Area ("EEA") (Amazon Web Services (AWS)) to host the information we collect, and we have safeguards in place to protect your information.
Unfortunately, the transmission of information (in particular, via the internet) is not completely secure. Although we will do our best to protect your information, we cannot guarantee the security of data transmitted either through the Website or by post, email or phone. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
We only keep personal information for as long as reasonably necessary to fulfil the relevant purposes described in this policy and in order to comply with our legal and regulatory obligations.
The Website contains links to other sites. Please be aware that Homegrown is not responsible for the privacy practices of such other sites.
Data Protection Laws give you certain rights in relation to your personal information, including the right to access, rectify, erase, restrict processing, transport (data portability) and object to personal information held about you.
You have the right to withdraw your consent and ask us not to process your information for marketing purposes at any time. You can exercise this right at any time by sending us an email to unsubscribe at firstname.lastname@example.org or by clicking the ‘unsubscribe’ link in any of our marketing communications.