1. Introduction
1.1 This website is owned and operated by WH Ireland Group plc (hereafter “WHIreland” or “we” or “our”) for itself and its affiliates and subsidiaries, including WH Ireland Limited.
1.2 WHIreland is registered in England and Wales under registration number 03870190 and its registered office is at 24 Martin Lane, London EC4R 0DR.
1.3 WHIreland’s Information Commissioner’s Office (ICO) registration number is Z620395X.
1.4 WHIreland recognises the importance of protecting your personal and financial information when you visit our website and is committed to safeguarding the privacy of its website visitors. In this Policy we explain how we will treat your personal information and also include our Cookie Policy which is designed to help you understand the information collection practices on our website. WHIreland will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website.
1.5 This Policy is dated 28 September 2021. Previous versions of this Policy are available upon request. We reserve the right to amend this Privacy Policy at any time without notice, by updating this posting, in which case the date of this Policy will be revised. The current version of this Policy can be accessed from the link on the homepage or at the bottom of our website page. By accessing our website following amendments, you are accepting the amended Policy.
1.6 We are registered as a data controller with the UK Information Commissioner’s Office.
1.7 You can contact us by writing to the business address given above, by using our website contact form, by email to enquiries@whirelandplc.com or by telephone on 0800 877 8866.
2. Collecting personal information
2.1 We may collect, store and use the following kinds of personal information:
(a) information about your computer and about your visits to and use of this website (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths);
(b) information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (including your name and email address);
(c) information contained in or relating to any communication that you send to us or send through our website (including the communication content and metadata associated with the communication);
(d) any other personal information that you choose to send to us.
2.2 Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with this policy.
3. Using personal information
3.1 Personal information submitted to us through our website will be used for the purposes specified in this policy or on the relevant pages of the website. The types of personal data that may be collected include your name, address, email address and telephone number. In addition, if you are accessing parts of this website that are password protected, then once you submit your password and enter, this website will recognise who you are and collect all information that you submit, including all electronic information (including all transaction information).
3.2 We may use your personal information to:
(a) administer our website and business;
(b) personalise our website for you;
(c) enable your use of the services available on our website;
(d) send you non-marketing commercial communications;
(e) send you email notifications that you have specifically requested;
(f) send you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter);
(g) send you marketing communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications);
(h) provide third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information);
(i) deal with enquiries and complaints made by or about you relating to our website;
(j) keep our website secure and prevent fraud;
(k) verify compliance with the terms and conditions governing the use of our website.
3.3 If you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the licence you grant to us.
3.4 Your privacy settings can be used to limit the publication of your information on our website, and can be adjusted using privacy controls on the website.
3.5 We will not, without your express consent, supply your personal information to any third party for the purpose of their or any other third party’s direct marketing.
4. Disclosing personal information
4.1 We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy.
4.2 We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.
4.3 We may disclose your personal information:
(a) to the extent that we are required to do so by law;
(b) in connection with any ongoing or prospective legal proceedings;
(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
(d) to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and
(e) to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
4.4 Except as provided in this policy, we will not provide your personal information to third parties.
5. International data transfers
5.1 Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy.
5.2 Information that we collect may be transferred to the following countries which do not have data protection laws equivalent to those in force in the European Economic Area: [the United States of America, Russia, Japan, China and India].
5.3 Personal information that you publish on our website or submit for publication on our website may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.
5.4 You expressly agree to the transfers of personal information described in this Section 5.
6. Retaining personal information
6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.
6.2 Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3 Without prejudice to Section 6.2, data will not be kept for longer than is necessary for the purposes for which it was collected or as required by law.
6.4 Notwithstanding the other provisions of this Section 6, we will retain documents (including electronic documents) containing personal data:
(a) to the extent that we are required to do so by law;
(b) if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
7. Security of personal information
7.1 We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
7.2 We will store all the personal information you provide on our secure (password- and firewall-protected) servers.
7.3 All electronic financial transactions entered into through our website will be protected by encryption technology.
7.4 You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
7.5 You are responsible for keeping the password you use for accessing our website confidential; we will not ask you for your password (except when you log in to our website).
8. Amendments
8.1 We may update this policy from time to time by publishing a new version on our website.
8.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
8.3 We may notify you of changes to this policy by email.
9. Your rights
9.1 You may contact us to:-
(a) request that we amend, rectify, delete or update the personal data we hold about you;
(b) where possible (e.g. in relation to marketing) amend or update your choices around processing;
(c) subject to the payment of a fee (currently fixed at GBP10 and the supply of appropriate evidence of your identity) request a copy of your personal data held by us.
9.2 We may withhold personal information that you request to the extent permitted by law.
9.3 In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
10. Third party websites
10.1 Our website includes hyperlinks to, and details of, third party websites.
10.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
11. Business Transfers
11.1 If the business of WHIreland or any part thereof is acquired or merged with another business entity, we will share all or some of your information with this entity to continue to provide our services to you. You will receive notice of such an event and the new entity will inform you of any changes to the practices in this Privacy Policy. If the new entity wishes to make additional use of your information, you may decline such use at such time.
1. Introduction
1.1 Our website uses cookies.
1.2 We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website. If you continue to use the website then we will understand that you consent to our use of cookies on your machine.
2. About cookies
2.1 A cookie is a small data file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Most website operators place cookies on the browser or hard drive of their user’s computer.
2.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
2.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies and can give you a more personalised web experience.
2.4 Cookies gather information about the user’s use of the website or enable the website to identify and track users as they navigate different pages on a website and identify users returning to a website. Cookies can also be used to collect information about the user which allows the website operator or a third party to create a profile of the user, their preferences and their interests for the purpose of serving the user with targeted, interest-based advertising.
3. Our cookies
3.1 Cookies help us to provide customised services and information. We use cookies on our website to tell us, in general terms, how and when pages in our website are visited, what our users’ technology preferences are and whether our website is functioning properly. If you are using one of our password-protected sites, then the website may use cookies or other technology to help us authenticate you, store and recognise your configuration and user attributes, facilitate your navigation of the website and customise its content so that the information made available is likely to be of more interest to you.
3.2 Essentially we use different types of cookies for specific purposes:
| 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. |
| Analytical / performance cookies | These are cookies which 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 are finding what they are looking for easily. |
| Functionality cookies | These are cookies which 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). |
| Targeting cookies | These are cookies which 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. |
More information about the individual cookies we use and the purposes for which we use them are set out below.
3.3 We use persistent cookies on our website. The names of the cookies that we use on our website, and the purposes for which they are used, are set out below:
| Cookie | Type | Purpose | Host |
| modal4720 | Strictly necessary | To track users’ acceptance of legal terms and conditions and information | WH Ireland |
| wordpress_test_cookie wp-settings-1 wp-settings-time-1 |
Strictly necessary | For the running of WordPress, the website Content Management System (CMS) | WH Ireland |
| whirelandCookies | Strictly necessary | To track acceptance of our terms and conditions and privacy and cookies policies | WH Ireland |
If you wish to know the retention period for data captured through these cookies, please refer to your investment manager.
3.4 We also use cookies for clients accessing the on-line client portal maintained by SEI Investments (Europe) Ltd. The names of the cookies used to access that part of our website, and the purposes for which they are used, are set out below:
| Cookie | Type | Purpose | Host |
| <username>
ArcotTC |
Strictly necessary | To record a user’s acceptance of the terms of use from the login enrolment process. During login, the system collects certain device characteristics and stores the information encrypted within a cookie. The user will be challenged to answer two security questions if the device characteristics do not match at least 60% with the previously collected information | SEI Investments (Europe) Ltd |
| Machine Fingerprint (MFP/DeviceID component) | Strictly necessary | This is stored after successfully registering the device. This cookie contains encrypted private/public key of the user. This key pair is used for password verification. If this cookie is deleted, the user will be challenged to answer two security questions | SEI Investments (Europe) Ltd |
| MFA Workflow (Arcot) ID ArcotAuthDid=<alpha string> | Strictly necessary | This is stored after the user successfully logs into the site after registering the device | SEI Investments (Europe) Ltd |
| GUEST_LANGUAGE_ID | Functionality | Indicates your language preference | SEI Investments (Europe) Ltd |
| COOKIE_SUPPORT | Strictly necessary | Indicates whether you support cookies | SEI Investments (Europe) Ltd |
| openglobal_privacy_widget | Strictly necessary | Indicates your acceptance of the cookie statement | SEI Investments (Europe) Ltd |
If you wish to know the retention period for data captured through these cookies, please refer to your investment manager.
3.5 We also use cookies for clients accessing the WH Ireland Investor Forum platform maintained by Delio Ltd. The names of the cookies used to access that part of our website, and the purposes for which they are used, are set out below:
| Cookie | Type | Purpose | Host |
| PHPSESSID | Functionality | This is a session ID for when someone interacts with the platform, each time a user logs onto the platform they are assigned this. | Delio Ltd |
3.6 We also use cookies for clients accessing the Research & Events Hub maintained by Research Tree. The names of the cookies used to access that part of our website, and the purposes for which they are used, are set out below:
| Cookie | Type | Purpose | Host |
| AspNet.ApplicationCookie | Functionality | This enables the application to use a cookie to store information for the signed in user. | Research Tree |
| ARRAffinity | Functionality | This cookie is set by websites run on the Windows Azure cloud platform. It is used for load balancing to make sure the visitor page requests are routed to the same server in any browsing session. | Research Tree |
| __RequestVerificationToken | Strictly necessary | This is an anti-forgery cookie set by web applications built using ASP.NET MVC technologies.It is designed to stop unauthorised posting of content to a website, known as Cross-Site Request Forgery.It holds no information about the user and is destroyed on closing the browser. | Research Tree |
| ai_user | Functionality | This cookie is used by Azure Application Insights to Detect issues, diagnose crashes and track usage in the web application. | Research Tree |
3.7 Please note that third parties (such as providers of external services like web traffic analysis services) may also use cookies over which we have no control. These cookies are likely to be analytical / performance cookies or targeting cookies.
4. Analytics cookies
4.1 We use Google Analytics to analyse the use of our website.
4.2 Our analytics service provider generates statistical and other information about website use by means of cookies.
4.3 The analytics cookies used by our website have the following names: _ga
4.4 The information generated relating to our website is used to create reports about the use of our website.
4.5 Our analytics service provider’s privacy policy is available at: https://www.google.com/policies/privacy/.
5. Blocking cookies
5.1 Most browsers allow you to refuse to accept cookies; for example:
(a) in Internet Explorer (version 10) you can block cookies using the cookie handling override settings available by clicking “Tools”, “Internet Options”, “Privacy” and then “Advanced”;
(b) in Firefox (version 24) you can block all cookies by clicking “Tools”, “Options”, “Privacy”, selecting “Use custom settings for history” from the drop-down menu, and unticking “Accept cookies from sites”; and
(c) in Chrome (version 29), you can block all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Content settings”, and then selecting “Block sites from setting any data” under the “Cookies” heading.
5.2 Blocking all cookies will have a negative impact upon the usability of many websites.
6. Deleting cookies
6.1 If you wish to remove cookies set by our website from your browser in the future, you may delete them. The instructions for removing cookies from your computer or mobile device depends on the operating system and web browser you use. You can delete cookies already stored on your computer; for example:
(a) in Internet Explorer (version 10), you must manually delete cookie files (you can find instructions for doing so at https://support.microsoft.com/kb/278835);
(b) in Firefox (version 24), you can delete cookies by clicking “Tools”, “Options” and “Privacy”, then selecting “Use custom settings for history”, clicking “Show Cookies”, and then clicking “Remove All Cookies”; and
(c) in Chrome (version 29), you can delete all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Clear browsing data”, and then selecting “Delete cookies and other site and plug-in data” before clicking “Clear browsing data”.
6.2 Please note, however, that withdrawing your agreement to the use of cookies on our sites will impair the functionality of the website.
7. Our details
7.1 This website is owned and operated by WH Ireland Group plc, ICO registration number Z620395X, for itself and its affiliates and subsidiaries, including WH Ireland Limited.
7.2 WH Ireland Group plc is registered in England and Wales under registration number 03870190. Its registered office and principal place of business is at 24 Martin Lane, London EC4R 0DR.
7.3 WH Ireland Limited is registered in England and Wales under registration number 2002044 and is authorised and regulated by the UK’s Financial Conduct Authority (Financial Services register number 140773). Its registered office and principal place of business is at 24 Martin Lane, London EC4R 0DR. WH Ireland Limited is a data controller and registered with the UK’s Information Commissioner’s Office under registration number Z5442086.
7.4 You can contact us by writing to the business address given above, by using our website contact form, by email to enquiries@whirelandplc.com or by telephone on 0800 877 8866.