Privacy Policy
- Important information and who we are
Forte Global respects your privacy and is committed to protecting your personal data. This privacy notice gives you information about how we collect and use your personal data through your use of our website and our services, including our AI language model ‘eSandro Intel Engine’ and our video training courses and masterclasses for financial advisors (collectively, the “Services”). It also tells you about your privacy rights and how the law protects you.
Who we are
This website is operated by Forte Global Limited (“Forte Global”, also referred to in this privacy notice as “we”, “us” and “our”), and our registered address is at 85 Great Portland Street, First Floor, London, England, W1W 7LT. We are registered with the Information Commissioner’s Office under number [INSERT].
Forte Global is the controller and responsible for the processing of your personal data as described in this privacy notice. Forte Global is referred to as "we", "us" or "our" in this privacy notice.
If you have any questions about this privacy notice, including any requests to exercise your legal rights (paragraph 9), please contact us at [email protected].
- What personal data do we collect?
We collect different information depending on how you use our Services and how you interact with us. 'Personal data' means any data that can be associated with you as an individual, either directly or indirectly.
- Identity Data includes your name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes your billing address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access the Services.
- Profile Data includes your password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you interact with and use the Services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any ‘special category’ personal data through our Services ('special categories' of data include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and health information). We also do not usually collect information about criminal convictions and offences.
We do not knowingly collect data relating to children under the age of 13.
- How is your personal data collected?
Different personal data is collected in different ways:
- Personal data you provide to us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you use our Services and create an account with us.
- Personal data we collect automatically. As you visit, use or interact with the Services, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please refer to ‘Cookie Information’ (paragraph 13 below) for further details.
- Personal data we receive from third parties. We receive personal data about you from various third parties. For example, we collect technical data from analytics providers, advertising networks, and search information providers. We also collect contact, financial and transaction data from providers of technical, payment and delivery services.
- How we use your personal data
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
- Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
- Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) 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).
- Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
- Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.
The table below set out a description of all the ways we use the various categories of 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.
|
Purpose/Use |
Type of data |
Legal basis |
|
To register you as a new customer |
Identity, contact |
|
|
To process and deliver your order including:
|
Identity, contact, financial, transaction, marketing and communications |
|
|
To manage our relationship with you which will include:
|
Identity, contact, profile, marketing and communications
|
|
|
To administer and protect our business and the Services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) including developing new products, services, features and functionality |
Identity, contact, technical
|
|
|
To deliver relevant website content and online advertisements to you and measure or understand the effectiveness of this advertising |
Identity, contact, profile, usage, marketing and communications, technical |
|
|
To use data analytics to improve the Services, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing |
Technical, usage
|
|
|
To send you relevant marketing communications and make personalised suggestions and recommendations to you about goods or services that may be of interest to you based on your profile data |
Identity, contact, profile, usage, marketing and communications, technical
|
|
Direct marketing
You will receive marketing communications from us if you have requested information from us.
Opting out of marketing
You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you. If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes.
Third-party marketing
We will always get your express consent before we share your personal data with any third party for their own direct marketing purposes.
Cookies
For more information about the cookies we use and how to change your cookie preferences, please refer to Cookie information (paragraph 13).
- Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table above.
- Service providers. We may share personal information with service providers that perform certain services on our behalf. For example, we may use service providers to process payments.
- 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 notice.
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.
- International transfers
Whenever we transfer your personal data out of the UK to countries whose laws do not provide the same level of data protection as the UK, we always use appropriate safeguards to ensure that your data is protected. In particular, we use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Agreement. To obtain a copy of these contractual safeguards, please contact us using our contact details below (paragraph 10).
- Data security
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.
- Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil 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.
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.
By law we have to keep basic information about our customers (including contact, identity, financial and transaction data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see paragraph 9 below for further information.
- Your legal rights
You have certain rights over your personal data. You may:
- require us to rectify the personal data we hold about you, where that data is incorrect;
- require that we restrict the processing of your personal information in certain circumstances;
- request access to the personal data that we hold about you;
- require that, in certain circumstances, we delete the personal information we hold about you;
- require that we provide you with the information that we hold about you in a structured, commonly used and machine-readable format; and/or
- withdraw your consent to our using your data for marketing purposes at any time.
You also have the right to lodge a complaint with the Information Commissioner’s Office (“ICO”), which is the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, be grateful if you would contact us in the first instance so we can endeavour to deal with your concerns direct.
If you wish to exercise any of these rights, please contact us at [email protected].
To protect your privacy and security, we will take reasonable steps to help verify your identity before granting access or making corrections.
- Contact details
If you have any questions about this privacy notice or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:
- Email address: [email protected].
- Postal address: 85 Great Portland Street, First Floor, London, England, W1W 7LT
- Changes to the privacy notice and your duty to inform us of changes
We keep our privacy notice under regular review. This version was last updated on the date set out above.
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, for example a new address or email address.
- Third-party links
The Services may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave the websites, we encourage you to read the privacy notice of every website you visit.
- Cookie information
Our websites use cookies to distinguish you from other users of our websites. This helps us to provide you with a good experience when you browse our websites and also allows us to improve our websites.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
We use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our websites. These essential cookies are always enabled because our websites won’t work properly without them. They include, for example, cookies that enable you to log into secure areas of our websites, use a shopping cart or make use of e-billing services. You can switch off these cookies in your browser settings but you may then not be able to access all or parts of our websites.
- Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our websites when they are using it. This helps us to improve the way our websites work, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise you when you return to our websites. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies. These cookies record your visit to our websites, the pages you have visited and the links you have followed. We will use this information to make our websites and the advertising displayed on it more relevant to your interests.
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
|
Cookie Title Cookie Name |
Purpose |
More information |
|
[COOKIE TITLE] [COOKIE NAME] |
[DESCRIPTION OF THE PURPOSE FOR WHICH THE COOKIE IS USED AND ITS DURATION] Examples of purposes for which a cookie may be used: This cookie [is essential for our site to OR enables us to]: [(a) Estimate our audience size and understand how our website it used.] [(b) Store information about your browsing preferences, and so allow us to customise our site and to provide you with offers that are targeted to your individual interests.] [(c) Speed up your searches.] [(d) Recognise you when you return to our site.] [(e) Allow you to use our site in a way that makes your browsing experience more convenient, for example, by allowing you to store items in an electronic shopping basket between visits. If you register with us or complete our online forms, we will use cookies to remember your details during your current visit, and any future visits provided the cookie was not deleted in the interim.] |
[LINK TO EXTERNAL INFORMATION WHERE APPROPRIATE] |
You can choose which analytical, functionality and targeting cookies we can set by clicking on the button(s):
Strictly necessary cookies ALWAYS ACTIVE
Analytical or performance cookies OFF
Functionality cookies OFF
Targeting cookies OFF
You can also choose to "Reject All" cookies in the cookie banner.
However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.
Except for essential cookies, all cookies will expire after [EXPIRY PERIOD].
If you have any questions or concerns about our use of cookies, please contact us using the information set out in the contact details section (paragraph 10).
