Ingenious Media Limited (the Company) and its subsidiaries or affiliates (we, our or us) are committed to protecting and respecting your privacy.

This policy (together with our Website terms of use and any other documents referred to) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of the Data Protection Act 1998 (the Act), the data controller is Ingenious Media Limited of 15 Golden Square, London, W1F 9JG.

Our nominated representative for the purpose of the Act is Sarah Cruickshank.


We may collect and process the following data about you:

  • Information that you provide by filling in forms on the Website or via the myIngenious service. This includes information provided at the time of registering to use our site, or requesting further services, as well as your continued use of the site and the myIngenious service. We may also ask you for information when you report a problem with our site.
  • If you contact us or use the myIngenious service, we may keep a record of that correspondence and usage.
  • We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
  • Details of your visits to our site and the myIngenious service including, but not limited to, traffic data, location data, and other communication data.


We may collect information about your computer, including, where available, your IP address, operating system and browser type, for system administration and to report aggregate information and occasionally to help improve the site. Generally, this is statistical data about our users' browsing actions and patterns, and does not identify any individual.

We may also obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive. In addition to enabling our Website and the myIngenious service to function as designed, these cookies may help us to improve our site and to deliver a better and more personalised service. They enable us to estimate our audience size and usage pattern of the non-secure areas of our Website where the information is collected in an anonymous form.

Where you have logged in to our secure area (including myIngenious) using a personalised user name and password, the type of cookie files placed onto your computer perform the following functions:

  • Strictly necessary cookies: These are cookies that are required for the operation of our Website including the myIngenious service. They include, for example, cookies that enable us to identify users and ensure that you can log into our Website and the myIngenious service, as well as access the user restricted pages on the myIngenious area. Typically, these cookies facilitate: general investor and adviser login; permitted adviser access to applicable investors’ summary information; and documentation links for both investors and advisers (as applicable and permitted).
  • Analytical/performance cookies: These cookies allow us to recognise and count the number of visitors and to see how visitors move around our Website and the myIngenious area when they are using either of them. This helps us to improve the way our Website and the myIngenious area work, for example, by ensuring that users are finding what they are looking for easily. Typically, these are third party analytics cookies which are used to track user login, pages accessed and use.
  • Functionality cookies: These are used to recognise you when you return to our Website or the myIngenious area. 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). As part of these kinds of cookies, your browser may offer the opportunity to remember your login details when you return to the site.

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access the myIngenious service or certain parts of our site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our site and the myIngenious area.


The data that we collect from, or about you may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.


We use information held about you in the following ways:

  • To ensure that content from our site is presented in the most effective manner for you and for your computer.
  • To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.
  • To carry out our obligations arising from any contracts entered into between you and us.
  • To notify you about changes to our service.

We may also use your data to provide you with information about goods and services which may be of interest to you and we may contact you about these by post, telephone or email.


We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.

We may disclose your personal information to third parties:

  • In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
  • If the Company or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use or terms and conditions of supply and other agreements; or to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.


You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before, or at the time of, collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at hello@theingeniousgroup.co.uk.

Our site may, from time to time, contain links to and from the websites of our partner networks and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies or the content of such third parties’ websites. Please check these policies before you submit any personal data to such websites.

The Act gives you the right to access information held by us about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee to meet our costs in providing you with details of the information we hold about you.


Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.


Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to hello@theingeniousgroup.co.uk.

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