Good Dividends

Your privacy is important to us and we want you to understand how when using the Good

Dividends online services, QuoLux™ Limited (“QuoLux™”) handles personal information.

Good Dividends.com is an open-source research platform (“website”) and the services on it are managed by QuoLux™.

QuoLux™ is committed to safeguarding the privacy of our users while providing personalised and useful services. This statement explains how QuoLux™ will collect, store, manage and protect your personal information. QuoLux™ will process your personal data in accordance with the General Data Protection Regulations (GDPR).

If you have any requests concerning your personal information, or any queries on these practices, please contact us by post or e-mail (see Contacting QuoLux™ below).

QuoLux™ may change this policy from time to time. This policy was last updated on 11th January 2022.

About Us

QuoLux™ Limited is a company registered in England and Wales (Company No. 06543734) with its registered office at B9 Elmbridge Court, Cheltenham Road East, Gloucester, Gloucestershire, GL3 1JZ, United Kingdom.

It is a UK based company that markets its services and programmes in countries around the world, so when you provide us personal data, that data may be used, processed, or stored anywhere in the world, including in countries that have data protection laws that are different to the country in which you reside. However, QuoLux™ has policies and procedures

in place that is constructed to safeguard and ensure an equal level of protection is applied across the entire organization and in accordance with this Policy.

QuoLux™ has an international division based in Brazil with staff who process and store personal information where required. For further information, please see ‘Security’ below.

QuoLux™ owns Good Dividends Ltd together with Professor Steve Kempster and this policy also applies to any data collected or generated by interacting with our open-source research platform, GoodDividends.com.

What type of information do we collect/hold?

QuoLux™ may collect, use, store and transfer different kinds of personal information about you, including:

a) Identity data, such as your name, marital status, title, date of birth, gender, job title and employer

b) Contact data, such as your home and work addresses, personal and work email addresses and personal and work telephone numbers

c) Technical data, including IP addresses, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website

d) Profile data, such as your username, password, your preferences, feedback and survey responses

e) Usage data, including information about how you use our website, products and services,

and

f) Marketing data, such as your preferences in receiving marketing from us and our third parties, and your communication preferences

How we collect your personal information

We may obtain personal information:

a) When you fill in forms on the website or engage with our online tools

b) When you correspond with us by phone, email, letters or otherwise

c) We may also obtain information automatically about you via automated technology when

you visit our website by using cookies, server logs and other similar technologies

How we use your personal information

We will only use your personal information when the law allows us.

We may use your personal information for a number of different purposes on the basis of

legitimate interest:-

• To communicate with you as a user of the online tools on our website

• To notify you about changes to our terms of business or this privacy policy

• To administer our website, and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, to allow you to participate in interactive features of our service, when you choose to do so, to measure or understand the effectiveness of advertising we serve to and recommendations to you and other users of our website about goods or services that may be of interest to you or them be of interest you or them.

• To ensure you receive the best experience possible when accessing and using our website. We will comply with our cookie policy when processing this information to provide you with information about special offers and other services we provide that are similar to those that you have already received from us.

• Where you have previously received marketing communications from us, to ensure you continue to receive communications that you have previously agreed to receive.

• To contact you by email to inform you of other relevant services that we provide (email marketing). For the purposes of email marketing, we will either ask you directly for your expressed consent or provide you with an opportunity to say no.

• Your information may be anonymised and used for research purposes. 

We will only use your personal information for the purpose(s) for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place sensible physical, electronic and

managerial procedures to safeguard and secure the information we collect including:

a) Secure lockable desks and cupboards. Desks and cupboards are kept locked when not in use if they hold confidential information of any kind.

b) Methods of disposal. Paper documents are disposed of by shredding in a manner that ensures confidentiality.

c) Our internal policies require that users lock or log off from their devices when they are unattended.

d) Electronic access. All data stored electronically is password-protected. Where we have provided an authorised user with a password, that user is responsible for keeping this password confidential and is not permitted to share the password with anyone.

e) If you have a username and password for any of the features on our website, you are responsible for keeping your password secret. You should not reveal your password to anyone. You should take reasonable precautions when using a computer that is not your own or in a public setting.

QuoLux™ makes every effort to protect personal information by users of the website, including using firewalls and other security measures on its servers. No server, however, is 100% secure, and you should take this into account when submitting personal or confidential information about yourself on any website, including this one. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Transfer / disclosure of personal information

Data may also be supplied to agents of QuoLux™ who provide services for QuoLux™.

QuoLux™ will obtain assurances from its agents that they will safeguard personal information in a manner consistent with this privacy policy.

As part of the services offered to you through this website, the information which you provide to us may be transferred to countries outside the United Kingdom (UK). For example, some of the data that we collect from you may be transferred to and stored in Brazil. It may also be processed by personnel operating in Brazil who works for us. By submitting your personal data, you agree to this transfer, storing or processing. These countries may not have similar data protection laws to the UK. By submitting your personal data, you’re agreeing to this transfer, storing or processing. If we transfer your information outside of the UK in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this Policy.

If you use our services while you are outside the UK, your information may be transferred outside the UK in order to provide you with those services.

Use of Website Cookies

When someone visits the website, our servers automatically gather the information that allows the site to communicate with the visitor’s computer during the visit. We also track the number of visits to the site and which parts of the site visitors select. We use those types of information for statistical purposes to help us administer and improve the site. Those types of information do not disclose personal information that would permit us to identify or locate individual visitors.

A cookie is a small piece of information sent by a web server to a web browser, which enables the server to collect information back from the browser. We use “cookies” to identify you when you visit the website. This enables us to build up a demographic profile of visitors to the site.

If you don’t want cookies to be stored on your device, you should make the necessary changes to your device or the relevant browsers or apps.

This website uses Google Analytics tracking software to monitor you to better understand how you use it. This software will save a cookie to your device in order to track and monitor your engagement and usage of the website, but will not store, save or collect personal information.

Social Media Platforms

We participate with social media platforms subject to their privacy policies and terms.

You should use social media platforms wisely and communicate/engage with them with due care and caution in regard to your own personal data. We will not request personal data through social media platforms. If you want to discuss something of a sensitive nature, then please use a more appropriate channel such as a telephone call or email.

This website may use social sharing buttons that help share web content directly from web pages to social media platforms. You should use these buttons with care. Note that the social media platforms may track and save your request to share a web page through your social media platform account.

We share web links on social media pages. Sometimes, these links can be shortened. These shortened URLs or even the displayed URL can be hacked or otherwise changed against our wishes to divert you to another site. We are not responsible if you are redirected to the incorrect site.

Links to other websites

Our website may contain links to other websites of interest. However, you should note that we do not have any control over these other websites. Once you have used any of these links to leave our site, therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting these sites and such sites are not governed by this privacy statement.

How long we will store your personal information

We retain information for as long as we reasonably require it for business or regulatory purposes. In the case of an individual interacting with our online research platform, Good Dividends.com, the retention period is 5 years.

Your legal rights

You have various legal rights in relation to the information you give us, or which we collect about you, as follows:

a) You have the right to request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

b) You have the right to object to stop using/storing your information where we are relying on a legitimate interest (or those of a third party). You also have the right to object to where we are processing your personal data for direct marketing. purposes. We will stop using/storing your information unless we can demonstrate that we have compelling legitimate grounds to process your information which override your interests, rights and freedoms.

c) You have the right to ask us to stop using your information where:

i. the information we hold is inaccurate;

ii. we are unlawfully using your information;

iii. we no longer need the information;

iv. we do not have a legitimate reason to use the information

d) You have the right to ask us to transfer your personal data to another person or company in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

e) You have the right to request that we correct your personal information if it is inaccurate or requires updating or completing your personal information if the information we hold is incomplete.

f) If we are processing your personal information on the basis that you have given your consent to us processing that personal information, you have a right to withdraw your consent at any time by using the “Contact Us” option on our website or by notifying us in writing, by email or by telephone.

g) You have the right to object to us using/storing your information for direct email marketing. You can use the unsubscribe link found in the email communication you receive from us or you can use the “Contact Us” option on our website or let us know in writing, by email or by telephone.

h) If you wish to exercise any of your legal rights, please contact us in writing, by email or by telephone.

i) If you are not satisfied with how we manage your personal data, you have the right to make a complaint to the Information Commissioner’s Office (https://ico.org.uk).

Children’s data

At QuoLux™, we do not market to children. Our websites are designed and intended for use by adults.

If we discover that we have collected personal data from a child without consent from a parent or guardian, we will delete that personal data as soon as practical.

Changes to our policy

Any changes we make to our policy in the future will be posted on our website and, where appropriate, notified to you by email or via social media. Please check our website frequently to see any updates or changes to our policy.

Contacting QuoLux™

If you have any questions, comments or complaints about this Privacy Policy, please contact us using the details below:

By post – QuoLux™ Ltd, B9 Elmbridge Court, Cheltenham Road East, Gloucester,

Gloucestershire, GL3 1JZ, United Kingdom

By email - [email protected]

By phone - +44 (0)1242 386880