Mellstock Privacy Policy

1. Introduction
We appreciate the trust you place in us when sharing your personal data. The security of that data is very important to us. In this document, we will explain how we collect, use and protect your personal data.

We will also explain what rights you have with regards to your personal data and how you can exercise those rights.

Personal data
Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as: “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
Mellstock Limited. How we use your information This privacy notice tells you how we, Mellstock Limited, will collect and use your personal data as follows:
- Visitors to our websites
When visitors arrive on www.mellstock.com , www.mellstockstrategic.com, www.thefundsworkshop.com, or www.studivest.com we use a third part service, which is google analytics, we use this to collect from you basic internet log information and information on your behaviour patterns while your on the site. This information lets us know how many visitors come to the site and what pages they are looking at and the amount of time they spend on certain pages. The information collected can not identify anyone and we ensure ourselves and google do not use this information to identify an individual of someone who has or is visiting our site.If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
- How Mellstock Limited Use Cookies
You can learn more about our cookie policy below.

E-newsletter We will send out a newsletter to people who have explicitly expressed they want to be contacted with a newsletter and selected email as their preference for receiving this by selecting the relevant box on our enquiry form.
Security and performance We use a third party programme to protect our website from malicious malware and attacks which means it will check your IP address on arrival.
People who contact us via social media We will contact you back on the platform you contacted us and we would always request explicit consent if you wanted us to send an email or contact you via phone.

Who we are

Mellstock Limited is the parent company for a number of websites and brand names, such as The Fundsworkshop and Studivest. The full list can be found in section 3 below along with their associated websites.

Mellstock Limited is the data controller for all the brands within the group. This means that Mellstock Limited determines what data is collected by each organisation within the group, how this data is going to be used and how this data is protected.

Our registered office address is:

Mellstock Limited

Charilaou Panagidi 6 Parekklisia Limassol 4520 Cyprus

If you have questions about how we process personal data, or would like to exercise your data subject rights, please email us at info@mellstock.com.

Companies and websites within scope

The following brands and websites are within scope for this privacy policy:

Mellstock Limited	www.mellstock.com
Mellstock Strategic	www.mellstockstrategic.com
The Funds Workshop	www.thefundsworkshop.com
Studivest	www.studivest.com

Unless specifically stated, we consider these websites to be Cyprus based websites; see section 6 below for more information on non-EU data processing.

It includes personal data that is collected through our websites, by telephone, through email and through any related social media applications.

Collection of personal data

We collect personal data from you for one or more of the following purposes:

1. To provide you with information that you have requested or which we think may be relevant to a subject in which you have demonstrated an interest;
2. To initiate and complete commercial transactions with you, or the entity that you represent, for the purchase of products and/or services;
3. To fulfil a contract that we have entered into with you or with the entity that you represent;
4. To ensure the security and safe operation of our websites and underlying business infrastructure, and
5. To manage any communication between you and us.

The table in Section 5 below provides more detail about the data that we collect for each of these purposes, the lawful basis for doing so, and the period for which we will retain each type of data.

Technical information

In addition, and in order to ensure that each visitor to any of our websites can use and navigate the site effectively, we collect the following:

Technical information, including the Internet Protocol (IP) address used to connect your device to the Internet;
Your login information, browser type and version, time zone setting, browser plug-in types and versions;
Operating system and platform;
Information about your visit, including the Uniform Resource Locators (URL) clickstream to, through, and from our site.

Our cookies policy, which can be viewed from the home page of each of our web sites, describes in detail how we use cookies.

In Section 8 below, we identify your rights in respect of the personal data that we collect and describe how you can exercise those rights.

Lawful basis for the processing of personal data

The table below describes the various forms of personal data we collect and the lawful basis for processing this data. Our business architecture, accounting and systems infrastructure and compliance organisation means that all personal data is processed on common, Group-wide platforms. We have processes in place to make sure that only those people in our organisation who need to access your data can do so. A number of data elements are collected for multiple purposes, as the table below shows. Some data may be shared with third parties and, where this happens, this is also identified below.

When we process on the lawful basis of legitimate interest, we apply the following test to determine whether it is appropriate:

The purpose test – is there a legitimate interest behind the processing?

Necessity test – is the processing necessary for that purpose?

Balancing test – is the legitimate interest overridden, or not, by the individual’s interests, rights or freedoms?

Purpose of collection	Information category	Data collected	Purpose for collection	Lawful basis for processing	Data shared with?	Retention period
1. To provide you with information	Subject matter information	Name, company name, geographic location, email address, business sector.	To provide appropriate online or email information about products and services that you have requested	Contractual fulfilment	Internally only	Maximum 8 years from the data the information is collected. 6 months if a marketing email is left unopened
			To provide further, related, online or email information and ongoing news updates in relation to the identified area of interest.	Legitimate interest	Internally only
		Telephone number	Follow-up to ensure requested information meets needs and identify further requirements	Legitimate interest	Internally only
		Personal contact information as provided through website forms or at trade shows or any other means.	General mailing list subscription	Consent	Internally only
2. Transactional information	Transaction details	Name, physical address, email address, telephone number, bank account details (for credit accounts), other medium of content delivery	To process purchase transactions for products and services with customers, and to ensure any transaction issues can be dealt with.	Contractual performance	Internally only	Maximum 8 years from the date of the performance of the contract. 6 months from the data the data subject has input personal information but has not proceeded with a transaction. 8 years for VAT records from the performance of the contract
			For accounting and taxation purposes	Statutory obligation	Internally and professional advisers
			Documentation should any contractual legal claim arise	Legitimate Interest	Internally and professional advisers
	Payment card data	Primary account number (PAN), cardholder name, service code, expiration date	To fulfil purchase requests using payment cards	Contractual performance	Payment card companies, all in line with PCI DSS	Only retained whist authorisation is pending.
3. Security	Security information	Technical information, as described above, plus any other information that may be required for this purpose	To protect our websites and infrastructure from cyber attach or other threats and to report and deal with any illegal acts.	Legitimate interest	Internally, forensic and other organisations with whom we might contract for this purpose.	Relevant statutes of limitation
5. Communications	Contact information	Names, contact details, identification details	To communicate with you about any issue that you raise with us or which follows from an interaction between us.	Legitimate interest	Internally and, as necessary, with professional advisers.	Relevant statutes of limitation.

Our legal basis for processing for the personal data:

If you decided to enter into a business agreement with Mellstock Limited under the contract we will need to process your details to service your order.

The special categories of personal data concerned are:

We do not process any special categories. We have included a list of what these categories are for your records under GDPR.

Racial
Ethnic origin
Political opinions
Religious beliefs
Philosophical beliefs
Trade union membership
Genetic data
Biometric data
Health data
Data concerning a natural person’s sex life
Sexual orientation

By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified.

Consent is required for Mellstock Limited to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.

You may withdraw consent at any time by going to the contact form on our website, by email or by writing to our registered address above.

Storage of personal data

Mellstock Limited is a Cyprus-domiciled organisation whose primary offices are in Cyprus.

The majority of our websites and web applications are hosted in the EU and are accessed only by our EU-based staff.
Our customer relationship management, marketing and accounting systems for all our businesses are either EU-based or hosted by companies participating in the EU.
We use a wide range of Cloud Service Providers (CSPs) as part of our processing environment. Unless we specifically state otherwise, we are, in respect of all these CSPs, the data controller.
Unless we specifically state otherwise all of the CSPs that we use utilise EU-located processing facilities.
Our payment processors and banking arrangements are based in the EU.
We operate a data retention policy in respect of all data, whether paper-based or digital and those aspects of it which relate to personal data are contained in the table at 5, above.
With regards to any email communication from us, you have the right to opt out of receiving any further emails by clicking the unsubscribe button at any time.
For any of our social media accounts, you also have the right to opt out of any further updates by unfollowing any account at any time.

Security measures

We have what we believe are appropriate security controls in place to protect personal data. We do not, however, have any control over what happens between your device and the boundary of our information infrastructure. You should be aware of the many information security risks that exist and take appropriate steps to safeguard your own information. We accept no liability in respect of breaches that occur beyond our sphere of control.

Your rights as a data subject

As a data subject whose personal information we hold, you have certain rights. If you wish to exercise any of these rights, please email info@mellstock.com or use the information supplied in the Contact us section below. In order to process your request, we will ask you to provide two valid forms of identification for verification purposes. Your rights are as follows:

The right to be informed As a data controller, we are obliged to provide clear and transparent information about our data processing activities. This is provided by this privacy policy and any related communications we may send you.
The right of access You may request a copy of the personal data we hold about you free of charge. Once we have verified your identity and, if relevant, the authority of any third-party requestor, we will provide access to the personal data we hold about you as well as the following information:
a) The purposes of the processing b) The categories of personal data concerned c) The recipients to whom the personal data has been disclosed d) The retention period or envisioned retention period for that personal data e) When personal data has been collected from a third party, the source of the personal data
If there are exceptional circumstances that mean we can refuse to provide the information, we will explain them. If requests are frivolous or vexatious, we reserve the right to refuse them. If answering requests is likely to require additional time or occasions unreasonable expense (which you may have to meet), we will inform you.
The right to rectification When you believe we hold inaccurate or incomplete personal information about you, you may exercise your right to correct or complete this data. This may be used with the right to restrict processing to make sure that incorrect/incomplete information is not processed until it is corrected.
The right to erasure (the ‘right to be forgotten’) Where no overriding legal basis or legitimate reason continues to exist for processing personal data, you may request that we delete the personal data. This includes personal data that may have been unlawfully processed. We will take all reasonable steps to ensure erasure.
The right to restrict processing You may ask us to stop processing your personal data. We will still hold the data, but will not process it any further. This right is an alternative to the right to erasure. If one of the following conditions applies you may exercise the right to restrict processing:

a) The accuracy of the personal data is contested b) Processing of the personal data is unlawful c) We no longer need the personal data for processing but the personal data is required for part of a legal process d) The right to object has been exercised and processing is restricted pending a decision on the status of the processing

The right to data portability You may request your set of personal data be transferred to another controller or processor, provided in a commonly used and machine-readable format. This right is only available if the original processing was on the basis of consent, the processing is by automated means and if the processing is based on the fulfilment of a contractual obligation.
The right to object You have the right to object to our processing of your data where
- Processing is based on legitimate interest;
- Processing is for the purpose of direct marketing;
- Processing is for the purposes of scientific or historic research;
- Processing involves automated decision-making and profiling.

Contact us

Any comments, questions or suggestions about this privacy policy or our handling of your personal data should be emailed to info@mellstock.com

Alternatively, you can contact us at our global HQ using the following postal address or telephone numbers:

GDPR Compliance Manager Mellstock Limited Suite 302 Josephides Building 73B Agias Phylaxeos Street Limassol 3087 Cyprus

Telephone: +357 25 345 351 Fax: +357 25 345 353

Our office is open 9:00 am – 5:30 pm Eastern European Time, Monday to Friday. However; we will endeavour to get back to you as soon as possible should no-one be available at the time of your call.

Complaints

Should you wish to discuss a complaint, please feel free to contact us using the details provided above. All complaints will be treated in a confidential manner.

Should you feel unsatisfied with our handling of your data, or about any complaint that you have made to us about our handling of your data, you are entitled to escalate your complaint to a supervisory authority within the European Union.

Changes to our Privacy Policy

Any changes we may make to our Privacy Policy in the future will be posted on our website and, where appropriate, notified to you by email.

12. Cookie Policy

Mellstock Limited use cookies on our sites (www.mellstock.com, www.mellstockstrategic.com, www.thefundsworkshop.com, www.studivest.com ,) (our site, or our sites) for a number of purposes. They help us to provide you with a good experience when you browse our website, and also allow us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies. 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 website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of the e-billing services.

• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users find what they are looking for easily.

• Functionality cookies. These are used to recognise you when you return to our website. 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 website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose. You can find more information about the individual cookies we use and the purposes for which we use them below.

First-party (Mellstock Limited) cookies

This website will set some cookies that are essential for the website to operate correctly. These cookies, none of which capture personally identifiable information, are as follows:

• Visitor ID – this cookie is a numeric value that identifies unique visitors and provides coherence and consistency to a site visit;

• Page Number – this cookie identifies the page you are on;

• Session ID – this cookie identifies your website session;

• Test – this cookie checks whether or not your browser supports cookies;

• Order – this cookie ensures that your shopping basket works correctly.

Third-party cookies

Our websites will set several types of third-party cookie, and we do not control the operation of any of them. The third-party cookies which may be set include:

Google Analytics – we use Google Analytics to collect data about website usage. This data does not include personally identifiable information. You can view the Google Privacy Policy here: www.google.com/policies/privacy/.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. 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 site.