This privacy policy sets out how Cube Advisers Limited (CAL) collects, uses and protects your personal data.
CAL is the controller and responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy policy).
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. Any questions, queries or requests should be directed to: Jeff Pym, Chief Financial Officer, Cube Advisers Limited, 21a Kingly Street, London, W1B 5QA.
We keep our privacy policy under regular review. This version was last updated on 27 January 2025.
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.
Personal data means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity.
We use different methods to collect data from and about you including through:
Your interactions with us. You may give us your personal data by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
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:
We have set out below a description of the ways we use the various categories of your personal data, and which of the legal bases we rely on to do so.
| Purpose/Use | Type of data | Legal basis |
|---|---|---|
| To register you as a new customer |
(a) Identity (b) Contact | Performance of a contract with you |
| To process and deliver our services including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and 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) Dealing with your requests, complaints and queries |
(a) Identity (b) Contact (c) Marketing and 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 manage our relationship with you) |
| 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 |
(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 |
(a) Identity (b) Contact (c) Usage (d) Marketing and Communications (e) Technical | 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, customer relationships and experiences and to measure the effectiveness of our communications and marketing |
(a) Technical (b) Usage | 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 send you relevant marketing communications |
(a) Identity (b) Contact (c) Technical (d) Usage (e) Marketing and Communications | Necessary for our legitimate interests (to carry out direct marketing, develop our products/services and grow our business) or where Consent has been obtained |
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving the marketing.
We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.
You can ask to stop sending you marketing communications at any time. If you opt out, you will still receive essential service-related communications.
We may share your personal data with internal or external third parties such as IT providers, professional advisers, or authorities like HMRC where necessary.
We do not transfer your personal data outside of the European Economic Area (EEA).
We have implemented appropriate security measures to protect your personal data and have procedures in place in case of a breach.
We only retain your personal data for as long as necessary and may retain anonymised data indefinitely for research or statistical purposes.
You have the right to:
To exercise your rights, please contact our DPO.
We may request proof of identity before fulfilling your request and contact you for further information to expedite the process.
We aim to respond within one month unless the request is complex or there are multiple requests.
You have the right to complain to the Information Commissioner’s Office (ICO) at www.ico.org.uk. However, we would appreciate the opportunity to resolve your concerns first.